Collection Advisor March/April 2017

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Vol. 17, No. 2

NACS Dragon Boat 2016 Crew (Paddles Up!)

COLLECTION PRODUCTS & SERVICES DIRECTORY 5 BENEFITS TO HELP ATTRACT THE BEST TEAM AGENCIES IN THE COMMUNITY MAKE YOUR CALL RECORDING WORK HARDER HOW THE PRESIDENT WILL IMPACT DEBT COLLECTION

March/April 2017

3 TIPS TO GUIDE YOUR SKIP TRACING LITTLE KNOWN SITES TO FIND YOUR SKIP PROVIDING CLARITY TO AN EVOLVING TCPA COMMERICAL COLLECTION PROVEN TACTICS

Collection Advisor P.O. Box 92342 Southlake, TX 76092

16 THINGS YOUR LETTERS SHOULD HAVE

PRSRT STD US POSTAGE PAID COLLECTION ADVISOR

SKIP TRACING

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Debra J. Ciskey

6

Sam Eidson

8 Ron Brown 10

Fred N. Blitt

12

Harry A. Strausser III

14

Nick Jarman

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Sam Edens

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e m o c l e W T

he skip tracing issue is always a popular issue. Maybe it’s because skip tracing provides collection professionals the thrill of the hunt. Or maybe it’s because skip tracing has professionals stepping outside of their comfort zone and any wise advice is valuable. Either way this issue dispenses some quick tips from industry pros as well as great insight into one agency’s medical debt skip tracing efforts in this issue’s Agency Spotlight.

Compliance Advisor Debra J. Ciskey explains a few very good legal reasons why your letters to consumers should be as lowbrow as possible. Skip Tracing Advisor Ron Brown completes his trilogy on the invisible web and how this valuable resource can give your skip tracing efforts a significant boost. Legal Collection Advisor Fred N. Blitt gives his expert opinion on a topic everyone has been discussing in and outside of the collection industry: how will President Trump affect us? Blitt covers Trump’s documented stances and what they could mean for collectors. Technology Advisor Sam Edens explains how to differentiate skip tracing vendors who are basically selling the same information. Benchmark Advisor Harry A. Strausser III asks some tough questions about if working at your agency is worth it for your employees. Agency Advisor Sam Eidson covers collection letters and makes a few recommendations how not to get sued. Collection Industry Advisor Nick Jarman sums things up nicely into three things you should be doing for your skip tracing.

It is my hope you haven’t had too much of the government after the recent eventful presidential election. This is because next issue Collection Advisor puts government collections in the spotlight. We will also be taking a closer look at IVR and small office collection solutions. Until next time, we look forward to hearing from you.

T. Steel Rose CPA, ACS Editor

editor@collectionadvisor.com

Cornerstone Support.................................. Page 13 Advanced Payment Systems..................Page 28 Collect!................................................................Page 28 VoApps...............................................................Page 28 Quantrax...........................................................Page 29

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March/April 2017

Checklists and Training Tools

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CollectionAdvisor.com ACCESS ONLINE

USING TECHNOLOGY TO EMPOWER COLLECTIONS March/April 2017 |

ADVISORS 4

FEATURES

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COMPLIANCE ADVISOR

Why Your Letters Should Be Written for the Least Sophisticated Consumer Debra J. Ciskey

Providing Clarity to an Evolving TCPA ROBERT F. TOM AND BAKER DONELSON

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Credit Unions, Cell Phone Numbers, and the TCPA Are you Compliant?

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AGENCY ADVISOR

LINDA STRAUB JONES

16 Things Your Letters Should Have Sam Eidson

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SKIP TRACING ADVISOR

Little Known Sites to Find Your Skip The Invisible Web – Part 3 Ron Brown

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JOSHUA FLUEGEL

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I nsider Secrets About Skip Tracing Comparison Chart

BENCHMARK ADVISOR

5 Benefits to Help Attract the Best Team Harry A. Strausser III

JOSHUA FLUEGEL

25

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BENCHMARK ADVISOR

3 Tips to Guide Your Skip Tracing Through Turbulent Waters Nick Jarman

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Make Your Call Recording Work Harder for You JOSHUA FLUEGEL

C ollection Products & Services Directory

DEPARTMENTS

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TECHNOLOGY ADVISOR

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Agency Spotlight Focus on Skip Tracing To Reach Ultimate Goal

C ommercial Collection Proven Tactics

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Sam Edens

Agencies in the Community

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LEGAL COLLECTION ADVISOR

Differentiating in the Commoditized Skip Tracing Market

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Dallas S. Bunton, Sr., chairman and CEO of North American Credit Services

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How Will the Presidential Election Impact Debt Collection?

Fred N. Blitt

| Volume 17, No. 2

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Welcome

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Collection Industry Top Product Nominees

March/April 2017

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Receivables Management Expert

Why Your Letters Should Be Written for the Least Sophisticated Consumer ROUTING SLIP

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Initials

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One would think that as we enter the 40-year anniversary of the passage of the Fair Debt Collection Practices Act, norms for language in collection letters would be established and letters would not be the subject of litigation. However, as long as we have disagreement in the Circuit Courts, we will continue to experience controversy over letters. I have chosen several letter-related issues that were of concern in 2016.

Debra J. Ciskey The collection of time barred debt, especially when letters offer settlements without notification to consumers that the debt is time barred and that payment of the debt could result In an effort to save expense or expedite communications to in revival, continues to be controversial. The Third and Eighth consumers, it is a common practice to use a backer on collecCircuits, encompassing Pennsylvania, New Jersey and Delaware, tion notices that provides notification of all state-required dishold that in the absence of a threat closures in which the debt collector of litigation or actual litigation, no is licensed or may contact consumviolation of the FDCPA has ocers. These backers are sometimes “The Fifth, Sixth and Seventh circuits curred when a debt collector atclear about the extent to which have held that collection letters offering not tempts to collect on a potentially disclosures required by state law or time-barred debt that is otherwise regulation may be applicable to each to settle time-barred debts without valid. The Fifth, Sixth and Seventh individual consumer. In a 2016 case disclosing the status of the debt can be circuits have held that collection in Kansas, a debt collector lost its letters offering to settle time-barred motion to dismiss in a case in which misleading and therefore violate debts without disclosing the status its backer did not clearly disclose the FDCPA even if they of the debt can be misleading and that the Massachusetts disclosure retherefore violate the FDCPA even lating to a consumer’s right to cease do not expressly threaten litigation.” if they do not expressly threaten communication by a debt colleclitigation. The most recent case, detor at his place of employment was cided in the Fifth Circuit, (Daugherty v. Convergent Outsourc- applicable to Massachusetts consumers only. The court agreed ing, Inc.) cited the FTC’s “Repairing a Broken System” report with plaintiffs’ contention that the placement, bold font and on debt collection litigation and arbitration, published in 2010, all uppercase letters presentation of the notification could lead and enforcement actions in which debt collectors were required consumers to believe the disclosure applies to all consumers, not to inform consumers the debt collector cannot sue on a time only residents of Massachusetts. The court provided examples barred debt, and to inform consumers that providing a partial from other decisions which were decided for the debt collectors payment might revive the collectors ability to sue on the balance. in which they presented the state law requirements in a chart, The Fifth, Sixth, and Seventh circuits rely heavily on the least clearly identifying the language that was applicable to residents sophisticated consumer standard, asserting that most consumers of a certain state only. The least sophisticated consumer standard are not aware of the effect of the statute of limitations on debt was applied to the scenario. The court said the least sophistiand the fact that even a small payment can revive a debt that may cated consumer could be misled to believe the disclosure applies be ineligible for collection by litigation. to all consumers, not just Massachusetts residents. Because the

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“I have chosen several letter-related issues that were of concern in 2016.”

Massachusetts disclosure places an “in writing” requirement on consumers to permanently cease calls to them at their place of employment and the federal FDCPA does not, the prominence of the Massachusetts disclosure without an accompanying label can be a misrepresentation.

The reliance of the least sophisticated consumer standard remains the common thread in collection notice cases. Time, effort and care must be expended when revising existing notices or writing new collection notices. Just as you would when developing a presentation for new hires as compared to a presentation for clients, consider the audience for your letter. Make the assumption the letter will be examined under the least sophisticated consumer standard.

• Are you avoiding the use of industry or accounting jargon?

• Are you spelling out abbreviations, even those that you think are very common—for example, as you delineate which disclosures are applicable to residents of specific states, are you spelling out the name of the state?

• Is your attorney or compliance officer reviewing your new or revised letters?

• Who else can put eyes on your notices—for example, someone who might represent the least sophisticated consumer demographic?

Be sure you have a policy that describes the steps you take to ensure that your letters say what they mean and mean what they say, and document that you have followed the process for every revision or new letter you introduce.

There is an old adage in the collection industry that says, “letters don’t collect money, collectors collect money.” Rather than do what you have always done, take some time here at the beginning of the New Year to review your letters, retire those that are not profitable, and examine each one from a risk perspective. Sometimes letters cost more than they collect.

Debra Ciskey is the Compliance Officer at Wakefield & Associates.

Inc. She is a member of the board of directors and a certified instructor for ACA International.

16 Things Your Letters Should Have

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Collection letters have been a pain point for many agencies in recent years due to the constant change and new regulations. The FDCPA and multiple states have individual requirements that must be followed in order to remain compliant. Failure to comply can result in negative audit findings, fines and lawsuits. Most recently the New York State Department of Financial Services (NYSDFS) released a compilation of codes, rules and regulations including initial statute of limitations and substantiation disclosures, itemization, payment schedules, quarterly statements and email restrictions. Case law suggests that agencies itemize the initial letter to avoid unfair practices. It is recommended or in some cases required to have a collection attorney review your written correspondence annually for risk assessment. Below are a few suggestions:

1.

The text of each letter should be in black ink and not less than 11 point font size.

2.

The mini-miranda should be stated verbatim on all letters: “This communication is an attempt to collect a debt by a debt collector. Any information obtained will be used for that purpose.”

3.

The consumer name and address should be the only thing visible through the window envelope.

4.

Settlement offer letters should state the following language after the offer, “We are not obligated to renew this offer.”

5. Avoid using 1099c or IRS reporting language.

Required disclosures have increased at the state and federal levels as a way to protect consumers from unfair, deceptive or abusive acts or practices. In addition to the 30-day validation disclosure, agencies are also required to include specific state text, credit reporting, obsolete debt and in some cases safe harbor language. Below are some examples of the required disclosures.

When collecting debt that is 1) beyond the statute of limitations, 2) not too old to credit report or 3) you are credit reporting the account to one or more credit bureaus, your initial communication letter should contain the following disclosure on the front side of the letter:

6.

The law limits how long you can be sued on a debt.

Because of the age of your debt, we will not sue you for it. If you do not pay the debt, we may continue to report it to the credit reporting agencies.

When collecting debt which is beyond the statute of limitations and too old to credit report, your initial communication letter should contain the following disclosures on the front side of the letter:

7.

The law limits how long you can be sued on a debt. Because of the age of your debt, we will not sue you for it, and we will not report it to any credit reporting agency.

If the consumer is being charged any fee for any reason, including a convenience fee, vendor fee, payment processing fee,

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Agency Advisor Sam Eidson

the letter referencing the fee should contain disclosure which is truthful, clear, and prominent of the following information:

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The fact a fee will be charged.

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The amount of the fee.

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The number of times the fee will be charged.

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The reason for the fee.

12. How consumers can avoid paying the fee.

In preparation of the CFPB’s final rules, I have created a list of items from their proposed rules. Agencies should be prepared to satisfy the requirements below and will need to work with their letter vendor to ensure the necessary changes won’t impact timing of working accounts.

13.

The CFPB has proposed updates to the validation notice.

14.

The CFPB has proposed requiring a Statement of Rights be sent in the initial communication and after 180 days if no confirmed consumer contact.

15.

Are versions available in Spanish?

16.

Proposed disclosures for time barred, intent to sue and credit reporting on obsolete debts.

The expense and time invested to create, manage, update and send letters affect overall profit margin. Agencies typically have two options: 1) send only the required letters by law or 2) create a series of letters to be sent during the lifecycle of an account.

Agencies should analyze what letter strategy works best for their organization considering many factors including the type of account, duration of placement and return of investment. I suggest having a dedicated number assigned to your letters in order to fully understand the return on investment. Having a dedicated number allows you analyze key metrics such as right party contacts, number of payments and revenue generated. Divide the revenue generated by the cost of the letters to determine whether you are behind or ahead on cost.

Sam Eidson is the Director of Compliance for Delta Outsource Group, Inc. He also serves on the Board of Directors for the Missouri Collectors Association.

March/April 2017

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PROVIDING CLARITY TO AN EVOLVING TCPA

BY ROBERT F. TOM AND BAKER DONELSON

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n October 20, 2016, the United States Court of Appeals for the District of Columbia Circuit heard the muchanticipated oral arguments in ACA InternaRobert F. Tom tional, et al. v. Federal Communications Commission, No. 151211 (ACA Lawsuit). The ACA Lawsuit arose out of the Federal Communications Commission’s (FCC) June 2015 Declaratory Ruling and Order (2015 Order), which interpreted certain aspects of the TCPA. In the ACA Lawsuit, the petitioners challenge the FCC’s 2015 Order and argue that it is overly broad and arbitrary.

The three-judge panel which heard arguments consisted of Judges Cornelia T.L. Pillard, Sri Srinivasan and Harry Edwards. The three main issues they considered were: 1. The FCC’s interpretation of the definition of an automatic telephone dialing system (ATDS) and the meaning of “capacity” of an ATDS; 2.

The FCC’s overly broad standard for revocation of consent; 3.

The issue of a “called party” in the reassigned number context and the one-call safe harbor rule.

While the D.C. Circuit has yet to rule on any of these issues, it is expected to shortly. The determination of these issues, discussed in more depth below, will undoubtedly be important to clients involved in collection activities and hopefully provide some clarity on the TCPA.

Interpretation of an ATDS and the Meaning of “Capacity”

The TCPA defines an ATDS as “equipment which has the capacity – (A) to .com

March/April 2017

store or produce telephone numbers to be called, using a random or sequential number generator; and (B) to dial such numbers.” In its 2015 Order, the FCC opined that Congress intended a broad definition of ATDS and thus concluded that an ATDS need only have the “capacity” to dial random and sequential numbers, rather than the “present ability” to do so. “In other words, the capacity of an autodialer is not limited to its current configuration but also includes its potential functionalities.”

“FCC confirmed that a caller could even obtain a consumer’s prior express consent through an intermediary.”

In an attempt to show that its interpretation of an ATDS was not without bounds, the FCC stated further that “the definition of autodialer does not extend to every piece of malleable and modifiable dialing equipment that conceivably could be considered to have some capacity.” “[T]here must be more than a theoretical potential that the equipment could be modified” to satisfy the “autodialer” definition. The FCC used a rotary phone as the only example and stated that while “it might be theoretically possible to modify a rotary-dial phone to such an extreme” that it would satisfy the definition of “autodialer,” such a possibility is too attenuated for a rotary-dial phone to have the requisite “capacity” and be considered an autodialer.

In the ACA Lawsuit before the D.C. Circuit, a major focus of discussion was the FCC’s broad interpretation of “capacity” and the definition of an autodialer.

During oral argument, the petitioners

maintained that the FCC’s broad definition would include even ordinary smartphones because they have the capability to install and use applications to autodial. The panel recognized the petitioners’ concerns and agreed that the FCC’s definition could produce senseless results. The judges even raised the issue of whether a simple call made to someone’s relative using a smartphone would expose someone to potential liability under the statute. The judges acknowledged the difficulty of applying a 25-year-old statute to modern methods of communication that fall within the scope of the TCPA.

Establishing Consent and Revocation of Consent

Although prior express consent is required for autodialed calls, a caller need not obtain such prior express consent through any specified means. Indeed, the FCC confirmed that a caller could even obtain a consumer’s prior express consent through an intermediary. Based on a prior FCC order from 1992, the FCC reaffirmed in its 2015 Order that “persons who knowingly release their phone numbers have in effect given their invitation or permission to be called at the number which they have given, absent instructions to the contrary.”

As to the revocation of that consent, the FCC recognized in the 2015 Order that the TCPA does not speak directly to the issue. But, relying on the TCPA’s purpose, the FCC found that “any silence in the statute as to the right of revocation should be construed in favor of consumers.” “[C]onsumers may revoke consent in any manner that clearly expresses a desire not to receive further messages, and that callers may not infringe on that ability by designating an exclusive means to revoke.” Thus, Continued on page 9

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Little Known Sites to Find Your Skip The Invisible Web – Part 3

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In this issue, we will continue to explore the web data provided by several sites located on what is commonly referred to as the invisible web. These sites are certainly not your “beginner” or “skip guesser” sites. Most of them require certain advanced skills to manipulate and massage the data. For the professional tracer to obtain the desired information needed to complete their searches, it is imperative they possess the required skills and a thorough understanding of exact data extraction techniques.

I have visited and conducted searches on each of these sites to insure they are working and functional as of December 23.

www.findlaw.com The first site we will look at is Find Law.

My staff and I utilize the information on this site to gather information on legal issues. Our agency finds this site quite useful and easy to manipulate as it is organized by category. Besides the fact that you can gather information regarding certain areas of law we find this site most useful when our investigation requires that we locate and profile an attorney or legal firm. Knowing what attorney represents the subject of your investigation allows you to locate and read pleadings that may provide location information on the person you are tracing. I have used this site many times to locate the employment of a high-profile person.

www.magportal.com This has, in the past, been an outstand-

ing site to search for magazine articles that may have been written about the subject on which you are gathering trace data. The site is very easy to manipulate. You may obtain information by selecting the related area of employment and then entering the name of the person for which you are searching. For example, select the category of “Business” and then enter the name “Ron Brown” and you will view business articles where the name Ron Brown appears. My information indicates this site will cease entering new articles as of January 2016 but will continue to archive and allow access to the data prior to that date.

www.icpsr.umich.edu/icpsrweb/ICPSR/ Now we will explore one

of the largest meta data sites I have discovered on the hidden web.

I have found that this data source contained volumes of data, far beyond my original expectations. I also discovered that the contents are easily manipulated and massaged enabling the user to extract all types of information. The databank contains statistical information related to demographic and socioeconomic matters across the world. If you are searching international sources you will find information from publications from Africa, Asia, Central America, Europe, North America and South America. In the header, you will find “Data-Related Publications” and “Find Data.” Both of these are very useful. I would advise you to also look under “Resources for Students” where you will find “Using

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Skip Tracing Advisor Ron Brown

Resources for Instructors.” This is an excellent data-driven learning guide for sharpening your tracing and research skills.

https://catalog.gpo.gov/F?RN=827421134 This is a bonus, just

for the professional tracer. This is the government website which archives and allows accessibility to all government manuals and publications. You name the subject and if the U.S. Government has ever written about it. There are databanks which contain:

• The GPO Historic Shelflist, which is the U.S. Government Publishing Office’s (GPO) historic card catalog covering U.S. Government documents from the 1800s to October 1992.

• Electronic Titles, this catalog contains records for and links to Federal Government publications that are available online. Records date from July 1976 to the present.

• The Federal Depository Library Program (FDLP) Web Archive, which is comprised of selected U.S. Government websites, harvested and archived to create working “snapshots” of the websites at various points in time. The aim is to provide permanent public access to federal agency web content.

The catalogue of U.S. Government publications is the finding tool for federal publications that includes descriptive information for historical and current publications as well as direct links to the full document, when available. Users can search by authoring agency, title, subject and general keywords, or click on “Advanced Search” for more options.

I would also encourage you to try the federated search engine https://metalib.gpo.gov to retrieve reports, articles and citations by simultaneously searching across multiple U.S. Federal Government databases.

Ron Brown is a member of the National Association of Fraud Investigators and the author of “MANHUNT: The Book.” Contact him at rbrown2150@aol.com.

March/April 2017

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“According to the FCC, consumers have a right to revoke consent, using any reasonable method either orally or in writing, and callers may not limit a consumer’s right to revoke consent.”

Providing Clarity to an Evolving TCPA Continued from page 7 according to the FCC, consumers have a right to revoke consent, using any reasonable method either orally or in writing, and callers may not limit a consumer’s right to revoke consent. The FCC further stated that if any question arises as to whether prior express consent was provided by a call recipient, the burden is on the caller to prove that it obtained the necessary prior express consent.

At oral argument before the D.C. Circuit on this issue, the petitioners argued that the FCC’s 2015 Order is arbitrary and capricious and creates an undue burden on callers to keep track of the various modes by which consumers might try to revoke consent and that allowing consent to be revoked at any time and by any means does not reasonably in-

form companies of such revocation. The judges seemed to indicate agreement by acknowledging that companies may have trouble compiling individualized consent revocations. The panel further questioned whether such a task had a chilling effect on businesses making protected communications to customers who wanted to receive the communications.

The Meaning of “Called Party” and Reassigned Cell Phone Numbers

The TCPA states that it “shall be unlawful” to “make any call” using an autodialer or an artificial or prerecorded voice, absent certain exceptions, without the prior express consent of the “called party.”

However, in the 2015 Order, the FCC acknowledged that the TCPA does not

define “called party.” Based on “the structure of the TCPA,” the FCC interpreted “called party” to mean “the subscriber to whom the dialed wireless number is assigned” and “a non-subscriber customary user,” both of whom can give prior express consent to be called at that number. In arriving at this definition, the FCC rejected “called party” to mean the “intended recipient” or “intended called party.” The FCC supported its rejection by finding caller intent absent from the TCPA. Problems with consent and revocation of consent arise, however, when a number has been reassigned to another user. In the FCC’s analysis, a caller may rely on the valid consent of a consenting party until that consenting party revokes the consent and opts out of calls, but the subscriber or customary user of a reassigned number Continued on page 11

One vendor. All the solutions.

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March/April 2017

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How Will the Presidential Election Impact Debt Collection?

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With all the articles we have seen on the CFPB and debt collection, I could not pass up the opportunity to write about this topic after the surprise election of Donald Trump as the next president.

Please keep in mind that this article is being drafted a month before Trump actually takes office so this will be a test of my political prognostication skills. As we know, the CFPB was created in 2010 as part of the Dodd-Frank financial reform legislation in response to the behavior of many companies on Wall Street.

While some of you might think Trump’s election signals the end of the CFPB, I would recommend that you don’t reassign your compliance management staff to new positions just yet.

The CFPB has been under attack since its inception and, most recently, the Court of Appeals for the District of Columbia potentially weakened the CFPB by ruling that its structure was unconstitutional. Under the ruling in the PHH case (a case involving a mortgage lender), the Court found, as structured, the CFPB director was the second most powerful official in the U.S. Government because his power was unchecked by presidential oversight. Other agencies operate at the direction of the president and thus are removable at will. As a result, the court ruled that the Agency’s director can be removed at the President’s discretion rather than “for cause” as under Dodd-Frank. This case combined with Trump’s contention that he will decrease regulations on businesses certainly leads us to believe that the next administration will decrease the regulatory impact on all of us.

In theory, these circumstances could lead to beneficial change for debt collection law firms. Notwithstanding, if I look into my crystal ball, I don’t see many changes anytime soon for a couple of reasons:

Consumer Benefit

The last few years of regulation have caused our banking clients to focus more on the consumer experience when dealing with their debt collection cases. While firms like mine have always treated consumers with dignity and respect, this treatment now is all part of standard practice. It is written in standard operating procedures and its effectiveness is audited by our clients. No matter what happens with the CFPB, this treatment is here to stay.

Consent Orders

We have seen a number of Consent Decrees involving companies and law firms over the past two years that impacts the manner in which we collect debt. For legal debt collections, the requirements are far in excess of what is required by our state codes of civil procedure (and please don’t get me started

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Legal Collection Advisor Fred N. Blitt

with the discussion of how the CFPB can override a code of civil procedure or a state’s right to regulate its own legal professionals). Nonetheless, the impact of this regulation on law firms is the increased amount of documentation that we now add to all complaints versus what is actually required by state law.

Hopes for Reduced Regulation

For me, I have always been in favor of helping the consumers navigate their financial problems. They should know the nature of their debts and we should work with them towards resolution. No one, not our clients or our firms want to file suit; we would rather resolve matters prior to going through the time and expense of a lawsuit. But, in the end, if the legal process must be exercised to enforce the collection of legitimate debts, then so be it. The problem today is that collection law firms are small and medium sized businesses just like any other business.

Increased regulation is a cost that is very hard for most businesses to afford as it does not produce any revenue. In my firm, we have a number of call monitoring associates, an internal audit team, a compliance counsel and a group dedicated exclusively to client external audits. I know that all of you have the same needs to address in your offices as well. All of those positions cost significant money and, combined with increased taxes, put a heavy strain on businesses to maintain profitability. All of our employees want salary increases, bonuses and increased benefits just like all other employees and consumers do. I’m hoping the change in administration will help level the playing field so that costs of regulation to the business are considered before legislation is enacted or new rules are issued.

Fred N. Blitt, Esq., is a partner with Blitt and Gaines, PC in Illinois and Couch, Conville and Blitt in Louisiana. He is past president of NARCA. March/April 2017

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“According to the FCC, consumers have a right to revoke consent, using any reasonable method either orally or in writing, and callers may not limit a consumer’s right to revoke consent.”

Providing Clarity to an Evolving TCPA Continued from page 9 has never consented. The FCC further reasoned that the consumer who inherits the wireless number neither expects nor desires these calls. However, the FCC recognized that making calls to reassigned numbers subject to liability under the TCPA could chill expected and desired communications. Thus, the FCC found that the first call to a wireless number after reassignment should not be subject to liability, absent actual knowledge of reassignment, but rather may act as an opportunity for the caller to obtain constructive or actual knowledge of reassignment. In balancing the caller’s interest in having an opportunity to learn of reassignment against the privacy interests of consumers who have a reassigned number, the FCC found a one-call safe harbor:

provided by the original subscriber when the caller makes the first call without reaching that original subscriber.

If the FCC’s statement regarding actual or constructive knowledge seems unworkable, it has been challenged as such.

During oral argument before the D.C. Circuit panel, the petitioners characterized the imposition of liability when no one answers the “one call” as “completely irrational” because it does not necessarily provide actual or constructive knowledge.

For example, a caller could reach voicemail that does not disclose the recipient’s identity. The judges, seemingly in agreement, questioned whether there is sufficient constructive knowledge of reassignment when a call is made to a reassigned number and the call goes to voicemail with no identifying information or ability

of the caller to identify the current cellphone subscriber.

Conclusion

The D.C. Circuit is expected to issue a decision in the forthcoming months on these issues, and hopefully will scale back the FCC’s overbroad interpretation of the scope of the TCPA and provide the business community some necessary clarity.

The D.C. Circuit’s opinion is obviously of great importance to clients with internal collection departments or engaged in debt collection. Stay tuned.

A shareholder in Baker Donelson’s Memphis office, Robert F. Tom represents clients in litigation involving contract disputes, consumer banking and finance disputes, commercial torts, and real estate and residential mortgage disputes.

He can be reached at rtom@bakerdonelson.com.

[W]here a caller believes he has consent to make a call and does not discover that a wireless number had been reassigned prior to making or initiating a call to that number for the first time after reassignment, liability should not attach for that first call, but the caller is liable for any calls thereafter. The caller, and not the called party, bears the burden of demonstrating: (1) that he had a reasonable basis to believe he had consent to make the call, and (2) that he did not have actual or constructive knowledge of reassignment prior to or at the time of this one-additional-call window we recognize as an opportunity for callers to discover reassignment.

The FCC went on to say that when the new subscriber to a reassigned number has not consented to the calls, the caller may reasonably be considered to have constructive knowledge – if not actual knowledge – of the revocation of consent July/August 2015 www.CollectionAdvisor.com .com March/April 2017

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5 Benefits to Help Attract the Best Team

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All collection firms and collection departments like to believe they offer staff members a good career opportunity. We work hard at creating a public perception and an internal culture that embraces the wants and needs of the contemporary workforce.

We strive to understand what employees really value relative to the dynamics of their careers and daily work experience. When we are fortunate to develop a good pool of employees we want them to stay with us for as long as possible. But, what are the triggers for making your office a place that people want to enjoy for the long haul?

One of the most common topics that arise in managementlevel programs surrounds a popular discussion on benefits and what other companies are doing to attract and maintain a happy, productive and loyal team. Years ago, most firms offered a salary or hourly wage, health insurance, sick time and vacation time.

There wasn’t a great deal of variation from one firm to another, especially with collection related positions. Now, times have changed and organizations struggle to find the right formula for benefit success.

What benefits do firms offer today? Here is some information I have compiled from feedback in seminars over the last two years:

Health Insurance There have been dramatic changes in what

companies offer relative to health insurance over the past 20 years.

Many firms at one time covered 100% for individual plans. As time went by and premiums rose sharply firms reduced their share to 50% and increased deductible and copayments to lower premiums. Some organizations simply could no longer afford insurance and dropped plans all together. It is a rarity today to find firms that cover the entire premium. With the introduction of the Affordable Care Act, many agencies dropped company plans and allowed employees to obtain coverage at lower rates in the marketplace. Wage increases were then offered to cover the expense. As premiums are dramatically on the rise once again, this continues to be a focal point of employers throughout the industry.

Supplemental Insurance As a service to staff, a growing number

of companies are offering access to supplemental insurance plans through companies like Aflac. These plans may include dental, life, cancer coverage and can often be introduced in such a manner that premiums can be paid prior to payroll taxes resulting in tax savings that, in many cases, fund the premiums. HR coordinators often have no cost other than coordinating the programs.

Sick Time The overwhelming majority of attendees at my semi-

nars have stopped offering sick time separate from vacation time

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Benchmark Advisor Harry A. Strausser III

and have lumped into paid time off or PTO. There are some states that have mandates on sick time so consult your HR professional.

Vacation Time Like sick time, most firms just offer a set number

of PTO days a year that you can use for any purpose. The number of days varies due to position and tenure and firms can choose between loading PTO every January 1 or an accrual method where PTO hours accumulate based on hours worked year to date.

Retirement Plans This is a benefit I feel is very important. Due

to the nature of our industry, we need to impress upon our employees the critical need to invest in their retirement futures.

There are many types of plans available. The most common are 401K and Simple IRA programs. They often include a company match of 1% to 3% of the staff member’s annual salary.

At a 3% match for an employee earning $40,000 per year, you would match contributions dollar for dollar up to $1200.00 for the year. A staff member could double their money annually by just investing $100 per month. As the math works, if a young employee is 25 and invests just $100 per month for 40 years until 65 in mutual funds that historically perform at 12% annual growth, they would have over $1 million when they retire!

Many firms today find that wages for collection staff are rather similar in a specific job market. What differentiates employers are often the physical facilities, general location (in town or out of town) and the attractiveness of benefit packages. Give careful thought to your benefit offerings in 2017. It could mean the difference between your firm being a good place to work or a great place to fulfill an entire career!

We encourage our readers to submit a “best practice” idea for inclusion in this column. Until next time, I’m in a collection office near you!

Harry A. Strausser III is president of Remit Corporation/Interact Training & Development. Contact him at harry@remitcorp.com.

March/April 2017

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COLLECTION INDUSTRY EVENTS Commercial Collection Agencies of America – Spring Meeting March 9 - 11 | Atlanta ACA International 2017 Spring Forum & Expo March 13 - 15 | Las Vegas Commercial Law League of America 2017 National Convention April 5 - 8 | Chicago NARCA – Spring 2017 Conference May 17 - 20 | Orlando International Association of Commercial Collectors Mid-Year Collection Conference July 14 - 16 | Seattle

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Ready for your next agency audit?

March/April 2017

Get a free coverage analysis by calling 770-626-7121 or www.cornerstonesupport.com/collectionadvisor

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3 Tips to Guide Your Skip Tracing Through Turbulent Waters ROUTING SLIP

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Skip tracing has always been one of the most highly contested aspects of debt collection from inside and outside the industry.

For some, skip tracing is viewed as an art form, highly coveted as a differentiator setting them apart from competitors. For others, skip tracing is looked at as a resource drain that doesn’t necessarily provide the return on investment for which they had hoped.

Regardless of the take on skip tracing there is one thing that is certain, skip-tracing as we have known it has been and will continue to evolve for better or worse. The days of obtaining and dialing evNick Jarman ery possible related phone number associated with the consumer, their friends, family, neighbors and employers are gone.

While the Consumer Financial Protection Bureau hasn’t consumer data from multiple sources, the reality is some data commented in depth about skip tracing activities, what they is more accurate and reliable than other data. The accuracy and have made clear is they will not tolerate third parties related or reliability of the data provided to your operation is critical. Havunrelated to the consumer of record being bothered while a debt ing an in depth understanding of this is very important. There collector seeks to establish communication. The expectation is are two types of data providers which I consider short-term and that a debt collector attempts to long-term providers. Short-term reach consumer(s) at the phone providers give you a lot of data, givnumber(s) provided by the coning the appearance their hit rate is “Be sure to include in your service sumer, or in the event the phone high. In reality the hit rate may be agreements language that requires number(s) are not available or no high while the quality rate may be longer valid, the debt collector low. Short-term providers are more the data providers to notify you takes appropriate steps to confirm interested in a quick buck than a before changing or adding sources any additional phone number dilong-term partnership. Long-term aled will lead to the consumer of providers look to become a partner, not mutually agreed upon..” record. That leads to the question, understanding your business needs what are the “appropriate steps?” and developing a strategy that values As with most regulatory and legislative direction, the ulti- quality over quantity while also focusing on being cost effective. mate answer is open for interpretation. Fortunately, we do have some insight and guidance to help steer our collective ships as Lastly, it is important to schedule regular safely as possible through turbulent waters. check ups with your data providers. Always remember to inspect what you expect. If your data provider is consistently providing The first step is to vet and know your a hit rate of 31% and then all of the sudden begins to provide data sources. When a provider of data approaches you to do a hit rate over 50%, this is cause for attention. This example of business, it is very important to find out who their data sources a spike in hit rates means something is most likely being done are and how they aggregate their data. It is not uncommon for with the data on the back end, whether the data provider opened data providers to withhold their exact sources of data. However, up the current sources or added news ones. Be sure to include in they should certainly be able to divulge the general sources and your service agreements language that requires the data providers type of data they aren’t just receiving, but more importantly pro- to notify you before changing or adding sources not mutually viding, since ultimately you are responsible for the data you are agreed upon. The days of setting and forgetting our data providreceiving regardless of how provided and where it came from. ers are now behind us. As our great President Ronald Reagan said, “trust but verify.”

Secondly, most data providers these Nick Jarman is the owner of RightAway Consulting & Coaching. Jarman days know which of their data sources are better than other served the last three years on the Board of Directors for ACA International elements of their data sources. Because data providers obtain and is the past President of the Missouri Collectors Association.

Collection Industry Advisor

Maintain Quality

Vet Data Sources

Choosey About Data 14

March/April 2017

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CREDIT UNIONS, CELL PHONE NUMBERS, AND THE TCPA - ARE YOU COMPLIANT?

BY LINDA STRAUB JONES

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here has been much coverage lately about credit unions potentially receiving a pass from the CFPB when it comes to rule making. But the same isn’t true for TCPA regulation. Every company that calls consumers on cell phones, no matter how big or small and no matter what the reason for the call, must Linda Straub Jones comply with the rules of the TCPA. Recently I participated in a webinar discussing the TCPA and credit unions, and was surprised to learn that the bulk of the webinar attendees are not being proactive when it comes to TCPA compliance. During the webinar, attendees were polled about their current TCPA compliance. The first question related to proactively identifying cell phone numbers in their accounts.

How Many Participants Scrub Cell Phone Numbers?

Of the attendees, 44% were not currently doing anything to identify cell phone numbers in their accounts. We live in a litigious society. Being unaware of which numbers in your accounts belong to cell phones could result in a violation of TCPA regulations—especially if your credit union has automatic dialing technology. Calling a credit union member on their cell phone without their express consent is a violation of the TCPA if you are placing that call via a telephone system that has automatic dialing capacity. Even if you are not presently using the automatic dialing function on your calling system, and even if your system doesn’t currently have that plug-in, you can still be in violation of the TCPA. Another question asked in the webinar pertained to whether attendees keep up with what is going on with TCPA cases and settlements in the news See Chart on Right: Again, the bulk of the attendees said they do not pay attention to what is happening in the news relating to the TCPA. This could also be a costly mistake. Even if your fellow credit .com

March/April 2017

unions aren’t hitting the headlines with violations, it doesn’t mean the same rules don’t apply to you, or you shouldn’t take time to be aware of what is going on in the credit and collections industry relating to TCPA activity.

It’s no longer only the regulators for which you have to watch out. Consumers are becoming much more savvy about screening incoming calls on their cell phones. We’ve seen a recent case where just one phone call to a consumer resulted in a lawsuit. In Sussino v. Work Out World (Case No. 15-cv-5881 (PGS)(TJB), United States District Court for the District of New Jersey), the plaintiff sued based on one phone call made to her cell phone, which she did not answer. However, a message was left, and she claimed that the one minute and six seconds it took her to pick up that message caused nuisance and invasion of privacy, trespass and interference with her rights and interest in her cell phone, intrusion on her seclusion, aggravation and annoyance, a waste of her time, loss of the use of her phone while listening to the message and depletion of her cell phone battery.

While we may agree that these claims are ridiculous—in fact, the judge thought so, too—the defendant still had to pay an attorney to defend those ridiculous claims.

There are many companies that offer cell phone identification. A simple scrub of your database to get a baseline, and then a monitoring solution to watch for changes in the status of phone numbers, can be a great insurance policy for your credit union. You can no longer afford to be in the dark when it comes to cell phone numbers in your portfolio.

Linda Straub Jones is the Director of Market Planning for Compliance Products with LexisNexis Risk Solutions. She has over 30 years of experience in the credit/collections industry and has worked as a collector, skip tracer and paralegal with a collections law firm. She can be reached at linda.straub@lexisnexis.com

How Many Participants Keep On Top of TCPA News?

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Differentiating in the Commoditized Skip Tracing Market

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Some time ago, the process of locating and gathering information about a debtor, or skip tracing, became a commodity. It is easy to get the information and the demand remains high.

However, there is little differentiation among those companies providing the data. When an end user is presented with new address or phone number data in the collection software, rarely do they know where the information came from. It is true some collection software platforms can track or flag the source of the data, but the source cannot be derived by simply looking at the data. Let’s look at the differentiation available and some ideas for agencies to streamline their skip tracing processes.

Skip tracing service providers offer a variety of solutions.

Free services, one-time fee services, real-time services and subscription services are commonly offered. Free skip tracing should be discarded. Although the obvious economic reasons are appealing, free skip tracing requires a staff, a high volume of manual intervention, inconsistency in effort and procedure and integration with the collection software, which is non-existent. You get what you pay for and free usually doesn’t cut it.

We have all heard this before.

One-time fee services are commonly referred to as batch skip tracing. Batch mode is generally very consistent and integrated. The data is requested and received one-time, usually overnight, and automatically fed into the collection software.

An agency can and should build all sorts of data handling rules to not only electronically load the data into the system but also set a level of reliability on the data and whether or not a verification process is required. What’s important is capturing all the data. After all, you are paying for it.

Batch is a good method when the agency has a need to process many debtors and having the updated information immediately is not important. Real-time services are similar to batch in terms of consistency and integration. The difference is in the timing. Real-time skip tracing is the fastest way to get updated or receive new information. It is usually accomplished in the collection software using a preprogrammed button or workflow where a request is sent to the service provider and a response is received real-time or near real-time. The concept of the data going straight into the software and the data handling rules as used in batch mode can apply.

A subscription model can be implemented for both batch and real-time. The beauty of a subscription model is that any debtors sent to the skip tracing service provider are “monitored” regardless of whether the request is sent in batch mode or real-time mode. This is attractive to agencies because the

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Technology Advisor Sam Edens

technology is always on. The provider will deliver a response on the initial request and monitor the debtor record for a predefined term. If at any time during the term the provider receives new information, it will automatically be delivered to the respective agency. Due to the nature of the service, the subscription model is commonly referred to as “monitoring.”

Excluding free services, technology and automation is largely well-defined and reliable in the skip tracing market.

However, skip tracing can be counterproductive. Too much manual intervention and the mixing of service providers can be expensive in terms of dollars and man hours. I believe 99% of all skip tracing efforts need to be electronic and automated in the collection software. Agencies should work to streamline skip tracing efforts by simplifying or eliminating waterfall models in an effort to find one sound service provider that can satisfy all the service models previously mentioned. There are providers who offer batch, real-time, subscription, and manual skip tracing services. While the first three are electronic and integrated with collection software, the manual service is simply a portal where the service provider allows end users to manually search the database for new information or to maintain the customers monitored database. Working with a provider like this can greatly streamline an agency’s skip tracing process.

Regardless of your skip tracing practice, don’t overlook the information from the original creditor. It is usually the most reliable. You want that information, so ask for it in the placement file and load any data point you receive somewhere in your technology enterprise. If you don’t need it today, it will be easier to locate when you do need it tomorrow.

Sam Edens has been with Emprise Technologies since 2006 and is currently serving as Vice President. Prior to his time with Emprise, Sam designed and developed performance and flow management software for UPS. March/April 2017

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AGENCIES IN THE COMMUNITY NACS 2016 American Cancer Society Corporate Impact Award Recipient

January 12, 2017 – North American Credit Services (NACS) was presented with the Corporate Impact Award by the American Cancer Society. This honor is awarded to companies that provide health information, programs, and benefits in each of the following four cancer prevention behaviors: physical activity, nutrition, tobacco, and cancer screening. “It’s exciting to be able to present such a distinguished award as this in behalf of the American Cancer Society, to a committed, local organization such as NACS and Medical Services here in Chattanooga,” said Melinda Craft, senior community engagement manager with the American Cancer Society’s Mid-South Division.

disease can quickly turn one’s life upside down and an important reason why his company consistently supports American Cancer Society’s charitable benefits over the years. “Not every story turns out like mine,” said Bunton. “Some have had more struggles, some did not make it through the struggle. Cancer events benefiting the local American Cancer Society, give us all a reason to come together to help make a collective difference. Let’s cure cancer!”

MRS BPO, LLC Collects Holiday Gifts and Shoes for Children in Need

December 20, 2016 – New Jersey-based debt collection agency MRS BPO, LLC continued its tradition of partnering with the Salvation Army to help provide gifts for children in need.

For the past seven years, MRS employees have brought joy to many children in the local community of Camden, New Jersey. The Salvation Army, through its Angel Tree program, provides new clothing, shoes, and toys for children of families in need through the support of local donors. The Salvation Army provides gift requests for children of all ages. These requests are printed Dallas S. Bunton, Sr. (center) with American Cancer on “angel” cards which decorate a tree Society reps Melinda Craft and Brennen Riddle at MRS’s office. Employees select a The American Cancer Society pres- card(s) from the tree and then purchase ents these awards annually as part of the the requested gift printed on the card for Society’s Corporate and Systems Initia- “their” child. For associates who do not tive, which creates meaningful, long-term have time to purchase a gift, the Salvarelationships with employers by engaging tion Army also accepts donations to purthem in delivery of the Society’s lifesav- chase gifts for children who may not have ing mission and support for its numerous had their tag chosen. programs and services.

Fifteen years ago NACS Chairman and CEO Dallas S. Bunton, Sr. was diagnosed with stage 3B Lung Cancer.

“Words can never even begin to describe what went through my mind as the doctors each told me of the diagnoses, along with the less then positive outlook for recovery,” said Bunton. “Now as a cancer survivor, I enjoy this wonderful blessing of life every day.”

Bunton knows all too well how this MRS BPO, LLC’s Salvation Army Angel Tree .com

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The delivery of donations has become a favorite tradition at MRS as employees collectively gave hundreds of toys and shoes recently to The Salvation Army Kroc Center in Camden, New Jersey.

“This year, The Salvation Army Kroc Center in Camden assisted over 500 families. We were blessed and overwhelmed by the generosity of many and were able to give more toys to more children,” said Major Susan Wood of The Salvation Army Kroc Center in Camden. “We are sincerely grateful to MRS Associates for their partnership in assisting local families in need.”

“The generosity and compassion of our staff never ceases to amaze us,” said Jeff and Saul Freedman co-CEOs of MRS. “We are proud of our staff and their contributions to our customers and to our local community.”

C B Merchant Services Give $135,000 in Grants

December 22, 2016 – C B Merchant Services recently announced grants totaling $135,000 have been made to 30 community benefit organizations in 2016.

This includes a grant to the California Association of Collector Educational Scholarship Foundation (CACESF) to promote financial literacy to graduating high school seniors.

“We’re proud to continue supporting organizations that help make our community a better place to live,” said, Linda Guinn, president of C B Merchant Services. CBMS granted $2,000 in support of the CACESF’s statewide competitive essay and scholarship program. Guinn commented, “CACESF’s essay contest is a wonderful vehicle to promote financial literacy on a statewide level.” The scholarship competition requires a simple one-page application and an essay on the importance of establishing and maintaining good financial credit during your college years.” The scholarship is available to any California high school senior for their use at any accredited college, university, or trade school.

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Focus on Skip Tracing to Reach Ultimate Goal

BY JOSHUA FLUEGEL

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ocus allows a collection professional to surpass all distraction and obstacles to achieve the ultimate goal: collect on an account. However, determining on what to Dallas S. Bunton, Sr. focus on and how best to go about it is why many consider collections to be an art. Collection Advisor spoke to Dallas S. Bunton, Sr., chairman and CEO of North American Credit Services (NACS) for this issue’s Agency Spotlight to learn more about the unique way they focus their skip tracers on objectives that help them reach their ultimate goal. We also learned about NACS’ company culture and how their focus on serving others has helped them all work in concert.

How did NACS come to be and describe its history with skip tracing?

NACS grew from a vision of healthcare executives in 1979 desiring to have a healthcare collection agency to support its national footprint. By 1982 I joined the healthcare group and worked for and in the development of the agency. With the entrance of computers still early in the game of operations, we actually still had a lot of work from data work cards (seriously old school). Skip tracing was all done manually. There were no automatic scrubs for phones, landline or cell, as today. All communication was done by making a call or sending a letter asking for information without disclosing why. That in itself was an art. Everyone answering the phone, it seemed, wanted to know who was calling and why… period. Of course at this time there were

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no consumer ad hoc programs for their phones, no caller ID and no number blocking. A good skip tracer with great voice tone and personality are worth their weight in gold. Through the years agencies and consumers have become more aware of systems, programs that help to avoid talking and skip tracing efforts. Still, a trained quality skip tracer with understanding of the what, who, when, where and how can uncover a stockpile of information that can lead to successful recoveries.

What kind of collections does NACS do and describe the part skip tracing plays in the process?

NACS is 100% healthcare. With all the overload of HIPAA and negative publicity surrounding healthcare accounts, collection and credit reporting of this debt causes a tremendous level of caution. Having access to the client’s system is vital and pieces of data are available

that often provides information regarding motor vehicle accidents (MVA) or insurance where the hospital may have the account flagged/registered as selfpay. Our company also subscribes to any electronic scrub on the market.

What is NACS’ philosophy when it comes to establishing and maintaining relationships related to skip tracing (vendor relations, informants, etc.)?

In healthcare the process is more straight up as far as the patient and responsible party is concerned. In healthcare we use client systems, available electronic scrubs and ACA schooled/trained skip tracers as necessary. Most often this has now become more of a specialty department due to insurances and MVA opportunities.

Can you describe this specialty department and how it would ideally be set up?

It goes back to training people to put

North American Credit Services collection floor March/April 2017

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“Remember, the recent case law last year said if a cell phone number is provided, that is mutual consent. We didn’t have that rule until 2016.”

them in a different frame of mind. As collectors, we have a frame of mind to turn as many accounts as we can for as many dollars as we can. In the long run it’s certainly going to be in our favor; we know what we are doing. But that doesn’t necessarily mean we work every account like we could. What we have developed over the past few years is a specialty area. We pay the people differently. We train them differently. We train them more like the old-school skip tracers but with a new flavor, a more technical environment for discovering and evaluating data.

We have a protocol where they know certain pieces of information they are looking for might get them into a third-party environment where there was a slip and fall or an MVA. All of those have a whole different set of questions. If the questions are similar, it’s the tone and the way you process the questions and how you evaluate the answers that might encourage you to continue and take more time. We recover quite a bit of money each month through the specialized department because they are paid differently, they slow down, they ask the who, what, when, where, why, how on almost every account. Most of the accounts they work are no less than $1,000 and go on up to $100,000.

What is an obstacle in skip tracing these days?

Consumer phone blocks, consumer recording and conversation to trick/deceive staff in to making a mistake while communicating, getting us sued. The longer we are on the call with a consumer the easier and more likely we are to say too much or the wrong thing. It has been this way for years. That has not changed.

What is NACS’ most valued technology in the recovery/skip tracing process? Why? Our trained staff because they “think.” .com

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Thinking allows us to try and test tools as they become available for positive results.

Karen James, Campus Collections Director for NACS, helping at 2016 event supporting Stop Soldiers Suicide Foundation

Is there a thought process or tactic you encourage in skip tracing efforts?

I’ve been doing this since 1973. In the beginning, as we progressed and began to have tools for skip tracing, we specialized. ACA trained skip tracers. We were separate from collectors because we had a different mentality and a different job. Through the years we’ve progressed to a more technical scrubbing environment where we don’t have to touch all the accounts. We just scrub them and score them and see what we can do. That works. We all know that the top 20% is paying 80% of the money, but you can get lost in that to the point where you don’t take your time training the people to be effective at what they do.

You set the bar differently for them in their commission. You make multiple systems available to them because you trust them to take the time. They’re not on this, “I’m going to do 15-24 calls an hour.” We don’t take these people and put them in that environment. I don’t care if you don’t work but five accounts

an hour. If you’re working large balance accounts, the money doesn’t often come in two, 10 or 60 days. These things often take months, especially when you’re dealing with an MVA or a thirdparty slip and fall. You have to have a person that has a lot of patience. They see the value of their time as they develop case after case. It’s almost like being a paralegal when you are developing your case knowing that the end result is going to be down the road. But when it hits, it’s going to be a windfall.

What is something you think has changed in skip tracing for debt collection in the past five years? Describe how this makes things better or worse.

I think the shifting of the telephone market, landline decrease, cell increase and knowing when and how to use each.

The necessary scrubs that are available are most helpful. However, understanding consent forms/signatures of cell use when in the registration process is a must. The correct wording by the service provider can make all the difference if a suit is filed.

Is there a particular wording that might land an agency in trouble?

It’s actually the lack of wording. Too often the hospitals have already set their consent forms in stone. They are already full of so much data because of Medicare and HIPAA. Four or five years ago agencies started getting sued because we were receiving sales numbers and there was no consent. If the hospital forms had simply said that patients agree and understand that the information that they’re providing is going to be used in all levels of communication in collection of the account, whether it’s insurance or a collection agency, that would have kept us safer. Remember, Continued on page 20

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Agency Spotlight

“A good skip tracer with great voice tone and personality are worth their weight in gold.”

Continued from page 19 the recent case law last year said if a cell phone number is provided, that is mutual consent. We didn’t have that rule until 2016. Prior to that it was just suit after suit and everyone was just fending for themselves. Of course ACA was putting out the verbiage hospitals should use on their consent forms. I was, like many other agencies, giving the verbiage to our clients. But the clients had to spend months going through their legal departments just trying to get consent forms changed.

what we do. We have blended operation in our company because we have some clients where we clearly have consent to use a cell number, and put it on our dialer, but in 50% of cases we don’t.

We have to do it old school by scrubbing the numbers first to make sure we know a landline from a cell number.

Then we have a compliance process for each one.

That’s what I’m talking about. You have to be more aware and communicate and engage more with the client because even clients are being sued now.

CEO Dallas Bunton, Sr. and staff at the NACS 2016 Chili Cook-Off Challenge

Our goal has been that we want to see the verbiage in the consent form allowing us to use a cell number on an auto-dialer. That’s what the issue is: Can a cell number be used on an auto-dialer? In a lot of cases up until just recently those consent forms were not available. Then what do you do?

You have to scrub all of your phone numbers through some of the providers to make sure the cell numbers are excluded from your auto-dialers. You can do the cold call like we did years ago without using your dialer. That’s

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What is one of the worst skip tracing-related mistakes an agency can make and explain how it can be avoided?

Not being prepared before a call is being made. Always review and study the account information. Determine how it got to this place: accident, purpose, lack of registration data or lack of verification during registration. Skip tracing when you are not prepared sets us up for failure and possible violations that can lead to poor client relations, poor customer relations and potential lawsuits.

How do you cultivate a positive and productive environment on the collection floor?

Culturally, we’ve always had an environment of willingness to serve. That’s probably one of the first questions we ask a person, if they know the definition of serving another individual. We explain that this is how we do it and ask if they can accept it and be part of this culture.

They must understand when you get someone on the phone you might be the one person who can make a difference in that person’s life. It isn’t all about collecting money. If you treat a person like a human being the money will eventually come. We’ve always cultivated that.

I’ve always owned my own company.

We have 300+ employees and we train them all the same way. Everyone buys in.

If they can’t buy in, they can’t stay.

How is NACS involved in the community?

NACS is involved in numerous community-based projects throughout the year.

They range from employees participating as a crew team in a healthy charitable competition alongside other businesses for a one-day festival on the Tennessee River which benefits the local children’s hospital to an annual chili cook-off competition held on the NACS campus in Chattanooga benefiting consumer financial literacy programs around the globe.

What is one tip you would give agencies regarding collections/skip tracing in the current CFPB and regulation-rich environment?

Be sure that you have a clear job description with defined processes that is understood by management and compliance. Then train, train and review work.

What do you like to do in your free time?

I enjoy reading and driving thru the country and enjoying the scenery. But when I can, I throw in a cruise in the Caribbean for good measure.

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COMMERCIAL COLLECTION PROVEN TACTICS

BY JOSHUA FLUEGEL

U

nfortunately a successful commercial collection effort does not begin on the collection floor. The process begins months, even years earlier. The taste of success becomes palpable when the agency’s upper management, the client and the collection floor are all working in concert with seamless handoffs of information through solid communication. Essentially, two aspects need to be functioning at optimal levels: the client and it’s commercial collection agency.

Your Agency

Commercial agency harmony should begin at the top in upper management and trickle down into middle management and then the collection and sales floors.

In contrast, data from the collection floor should be going up for upper management to consume.

“Collection managers should adhere to the principals brought together by upper management and pass those principals down to their teams,” said Bob Ingold Bob Ingold, president of Commercial Collection Corp. of New York. “Upper management should trust their managers to make decisions based on what they have learned. Results speak for themselves. Upper management should build checks to monitor activity.”

As process flows are established at all levels of the agency, a healthy influx of new clients will put the engine into high gear. The acquisition of new clients is a vital activity requiring careful consideration.

“The traditional methods of purchased lists and leasing Hoover’s desks [slots] still work but as the industry has shrunk over the recent years, new methods are required,” said Ingold. “Attending trade shows such as NACM (National Association of Credit Management), .com

March/April 2017

CRF (Credit Research Foundation) and ICTF (International Credit and Trade Finance Association) is helpful. Regional trade shows in industries such as insurance, manufacturing and transportation can also help. The modern sales person looks for leads in every part of this life; i.e.: the truck that just passed you, looking at products sold in stores for the manufacturer’s label, previous credit apps of placed accounts for similar companies. The successful sales person is always selling and always looking for new opportunities.”

“If you have had an issue with the customer in the past this shows them you will not allow them to make their own terms.”

Keeping all of these requirements in check would eventually become an easy task if it was not for the fact that debt collection is continually changing. In order to keep everything running on the agency side of the equation, leadership must be ready for change.

“Client relations and the service we provide are forever evolving,” said Ingold. “As client contacts are asked to do more with fewer resources, their needs are changing and they depend more on their agency to change accordingly. In many cases this makes the service more labor intensive, but necessary to work with that client. Also, as technology evolves, so does the need for instant gratification. In most cases, emails are available on smart phones, software platforms are personal device compatible, and client access portals are 24/7 accessible. The commercial collection industry will constantly evolve around the companies that use us.

Your Client

A well-functioning commercial collection agency is only half way to the overall goal. A successful relationship with clients will help ensure an agency’s longevity. The ideal relationship between an agency and a client is one where the client sees the agency as a source of account resolution and knowledge. Sharing some of the vast knowledge a commercial collection agency knows about accounts receivable will not only help the agency but help the agency in the long run. In an attempt to stay on top of accounts before they go into default, share the following tip with clients.

“Stay on top of your invoices at the 30-45 day mark,” said Ingold. “Staying ahead of the game and weeding out the stall tactics of ‘I do not have an invoice’ or ‘Can you send me a proof of delivery?’ early on will help you receive payment on time. Do not be afraid to pick up the phone and call your customer. It is easy for them to deny they received a letter or email. Verbal conversation goes a long way in recouping your funds.”

A client also needs to know when the ideal time to pass an account to a collection agency would be. Inform them that sooner is much better than later; inform them of the following: “Pass your customer and their payment history as early as 60 days,” said Ingold. “60 days seems to be early on, but if you have had an issue with the customer in the past this shows them you will not allow them to make their own terms. You want to start this process sooner rather than later as it’s always easier to recoup your funds early on in the aging process.”

If both the client and the agency are aware of each other’s needs, their relationship will be far more stress-free and profitable.

21

INSIDER SECRETS ABOUT SKIP TRACING

BY JOSHUA FLUEGEL

S

kip Tracing services is widely used by collection professionals, agencies and skip tracing professionals around the country. Such commonality and regular use usually lead to widespread misunderstandings and downright myths about the service and its functionality.

“Many of the skip tracing software packages that we see in the market today are lightly modified collection platforms,” said Stephanie Clark, president of VeriStephanie Clark Facts. “Most software developers believe there is a very tight correlation between skip tracing and collections, but in reality they function very differently. While collection software focuses heavily on payment processing and analytics around debtors where right party contact has already been made, skip tracing software needs to focus on being able to provide a consumer snapshot of all available lead generated information, area demographics and the ability to quickly and efficiently research and log skip results/attempts.”

An old school skip tracer would work on an account and then move on when they felt they found right information.

While this practice still exists for highdollar accounts, the vast majority is simply handled in large batches.

“When most people think of skip tracing software, they think about online platforms for manual searches,” said Chad Benson, president of Locate Smarter.

Chad Benson “However, there is now software available for batch processing too. This software can provide detailed reports/metrics, support skip tracing workflows, and even manage multiple vendors

22

– all on the same platform.”

Once a batch of accounts is back from the vendor and is populated with valuable information, is collection inevitable? It appears not. Not only is there still a possibility the information obtained through a vendor or in-house research can be wrong, it can become incorrect very quickly even if it started out accurate.

“In today’s world of instant communication, contact and social media it is expected that skip tracing software and the data returned should be 100% accurate, when in Jeff Flood reality due to the changing profile and borrowing and spending habits of today’s consumers, traditional ‘data sources’ of the past for skip tracers are not as accurate or updated as quickly due to the lack of information being reported,” said Jeff Flood, director at OneClick-Data.

“The popularity of social media has made more consumer information readily available for public access, however identifying the correct consumer has become more difficult since these sources do not contain SSN so they must use other unique identifiers to make connections.

Debt recovery companies and service providers will need to find new ways to use these public domain resources more effectively in order to make them viable data sources for their business needs.”

Should an account utilize and obtain as much data as possible? This is a difficult question to ask and the myths are even more difficult to debunk. Finding a good balance in the amount of data used in a search is important as an extreme on either end can lead to substandard results.

It is important to get as much helpful data as possible without treading into misleading information.

“The common myth about skip

tracing revolves around data quantity – the more data, the better,” said Sean Britt, Sr. Director, collections and investigations markets, LexisNexis risk soluSean Britt tions. “In fact, more data is not necessarily better to find a person. To have an effective skip-tracing program, collections professionals have to reduce the noise that a ‘more-data’ mentality can create and instead get to the right information faster.”

“Less is better for search input is a myth,” said Darren Charest, president of US Tracers. “Google doesn’t limit users to one or two searches for a reaDarren Charest son. Search algorithms should be able to use the extra input to find relevant results. Check with your data provider on their current best practices for searching.”

What is True? Just as it’s important to know what is not true about skip tracing software, it is important to dig through information and learn about the software’s less-known aspects. Such is the case with customization of the software. Customization can ease the software’s use as well as ensure proper functionality in conjunction with other tools in an agency’s toolbox.

“It’s difficult for skip tracing software and collections software to integrate well with each other,” said Clark. “The large amount of valuable information that can be returned from a successful skip will rarely all make it into a collection software screen. Collection professionals should constantly be ensuring that all information being provided from a skip platform is available for their collectors to leverage.”

“Most skip tracing software can be customized for the user/company,” said Benson “Whether it’s the searches visible to your collectors or the data sources used in a specific product, there are a handful of vendors willing to work with you to achieve a win-win.”

And of course, skip tracing is all about getting the right data at the right time. This also means being able to March/April 2017

.com

accept data from new kinds of sources.

“Skip tracing data provides unmatched data from consumer lending applications, contributory trade line sources and additional third party complied John Hambrick data,” said John Hambrick, SVP business development at MicroBilt. “Real-time data feeds keep data fresh and current and a proprietary scoring model delivers a score to help determine collectability.”

“The more data you can provide the software provider the better,” said Flood “DOB or an old address can be used to link to more current information on your debtor as skip tracing providers start to use more non-traditional data sources that may not include SSN.” Talk to the data providers/vendors to not only make sure they understand the agency’s needs but the agency understands the software and how it works.

“Most collections professionals don’t realize one of the key functionalities that enables their skip-tracing success is behind-the-scenes,” said Britt. “They never see it. That functionality is advanced analytics, which help agencies find the right people, fast. Analytics power decision transformations. For example, through analytics, professionals can have rankordered lists of prioritized people to contact. This drives operational efficiencies and helps agencies control the investment they are making in skip-tracing software.”

“Collection professionals can often better their desired search metrics by sharing their specific use cases with their data providers,” said Charest. “Be specific about what your goals are -- if you want to achieve the highest possible Place of Employment (POE) hit rate then share that. Also don’t skip the data provider’s training, it’s usually free and often there are hidden features, strengths, or weaknesses you’ll discover.”

Skip tracing is difficult enough without bad information floating around. Spending time with the software before hitting the trail will foster a more knowledgeable approach to the endeavor and disperse any myths surrounding the subject. .com

March/April 2017

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BUILD YOUR BRAND TO LAST

SKIP TRACING COMPARISON CHART PRODUCT

Accurint for Collections

CollectBOOST

LocateSmarter

POE, Banks, and Location Info

Payroll Promise

SPOT POE

Company

LexisNexis Risk Solutions

US Tracers

LocateSmarter

OneClick-Data

VeriFacts

MicroBilt Corporation

Accurint for Collections

CollectBOOST

LocateSmarter

POE, Banks, and Location Info

Payroll Promise

SPOT POE

Analytics

Yes

Yes

Yes

Yes

Yes

Yes

Batch

Yes

Yes

Yes

Yes

Yes

Yes

Online

Yes

Yes

Yes

No

No

Yes

Addresses

Yes

Yes

Yes

Yes

Yes

Yes

Phones

Yes

Yes

Yes

Yes

Yes

Yes

Asset info

Yes

Yes

Yes

Yes

Yes

Yes

Bankruptcy

Yes

Yes

Yes

Yes

Yes

Yes

Real estate owned

Yes

Yes

Yes

No

Yes

Yes

Purchase date

Yes

Yes

Yes

No

No

Yes

Loan amount

Yes

Yes

No

No

No

Yes

Tax bill address

Yes

Yes

No

No

No

Yes

Cohabitants

Yes

Yes

No

No

No

Yes

Relatives

Yes

Yes

Yes

No

No

Yes

Neighbors/nearbys

Yes

Yes

Yes

No

No

Yes

Known associates

Yes

Yes

Yes

No

No

Yes

Wireless phones

Yes

Yes

Yes

Yes

Yes

Yes

Alternative phones

Yes

Yes

Yes

Yes

Yes

Yes

BUSINESS TIES

Accurint for Collections

CollectBOOST

LocateSmarter

POE, Banks, and Location Info

Payroll Promise

SPOT POE

Officers

Yes

Yes

Yes

No

No

Yes

Employees

Yes

Yes

No

No

No

No

Co-workers

Yes

Yes

No

No

No

No

SSN

Yes

Yes

No

Yes

Yes

Yes

DOB

Yes

Yes

No

Yes

Yes

Yes

Place of employment

Yes

Yes

Yes

Yes

Yes

Yes

FUNCTIONALITY

Accurint for Collections

CollectBOOST

LocateSmarter

POE, Banks, and Location Info

Payroll Promise

SPOT POE

Account monitoring

Yes

Yes

Yes

Yes

Yes

Yes

Daily updates

Yes

Yes

Yes

Yes

Yes

Yes

Recovery reporting

No

Yes

No

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Payroll Promise

SPOT POE

FEATURES

Encryption

OTHER

Accurint for Collections

CollectBOOST

LocateSmarter

POE, Banks, and Location Info

Training

Yes

Yes

Yes

Yes

Yes

Yes

Consulting

Yes

Yes

Yes

Yes

Yes

Yes

24-hour service

Yes

Yes

Yes

Yes

Yes

Yes

Information on this table is derived from information posted on the Internet and direct questions. The company is the ultimate source and should be contacted directly.

24

March/April 2017

.com

MAKE YOUR CALL RECORDING WORK HARDER FOR YOU

R

ecording phone conversations between consumers and collection professionals is one of the best, if not the ultimate, methods of ongoing training and protecting an agency from lawsuits. Such a tool should not only fulfill all of an agency’s needs but also work as hard as the collection professionals themselves. To ensure an optimized call recording solution, several vendors offered their advice.

Among call recording software’s features, several may be overlooked by collection professionals. A solution’s ability to organize and store recordings long-term is one professionals should take care not to forget.

“The most under utilized call recording feature among collection professionals would be long-term call recording storage and a method to organize all those files,” Terrel Bird said Terrel Bird, CEO of TCN. “Being able to pull up specific call records on the fly not only helps stay within compliance and similar requests, but also agent training. Storing and organizing call records will also add another layer of data an organization needs to understand their clients.”

As compliance through security is paramount, recordings of phone calls must not be forgotten.

“Encrypted recordings. Call recordings are data and can contain protected information that was provided verbally,” said Jeff Dantzler, president of Comtronic Systems. “Therefore, all call recordings should be encrypted and you must be able to control the security as to who can review recordings.”

An agency could have the perfect call recording solution; one that satisfies every requirement of every stakeholder.

Unfortunately this alone would not spell out success. A call recording system must be able to integrate into an .com

March/April 2017

agency well, able to work in concert with every other resource. It is only at this point where a call recording system can truly work for an agency.

“Choosing a call recording solution that is directly integrated with your debt collection software is critical to ensuring auditing and compliance Jeff Dantzler at the account level,” said Dantzler. “If call recording is done right, it will link every call, in-bound and out-bound, to the debtor file with all the time and date stamps included.

Those recordings are equally as important to other debtor data and therefore should be part of the digital history of that debtor. Anything less than this is not satisfactory.”

Not only will this level of integration be advantageous for workflow and

BY JOSHUA FLUEGEL

software usage, a financial benefit may also be found.

“To ensure a successful integration, be sure to use a call recording tool that is integrated with your existing dialer or phone system,” said Bird. “This not only helps save time, but money also. By using a solution similar to this you’ll be able to keep track of all those recordings much easier.”

Due diligence is key to making a call recording solution work as hard for an agency as any other collection professional. If a tool is something to be owned and used, own all information about that tool and use it to your benefit.

CALL RECORDING SOFTWARE PRODUCTS Comtronic Systems TCN

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25

‘

ECONOMIC STIMULUS Collection Products

FOR YOUR BUSINESS

& Services Directory

Our economy and our industry are undergoing unprecedented change. It has never been more important that we understand and efficiently operate our businesses.

The Computer Collection For almost 40Software years our innovations have been a partner • No obligation efficiency analysis Manager, Inc. in our client’s success. We’re committed to providing • Credit for your Software existing software Debt$Net Collection Beam Softwarefresh ideas and developing creative solutions. As part • Free data conversion debtnet5.com of that commitment we’ve developed the CollectOne BEAM Accounts sales@debtnet5.com • Feature rich collection software Stimulus Plan, a cost-effective opportunity to help you Receivable 800-552-8397 • Deferred payment options ensure that your business is best managing change.

Management Software, Since 1987, Debt$Net collectionoptions software has provided • No interest financing Beam Cell Phone Identification Software agencies, law firms and in-house collection Learn more about CollectOnecollection • Free third-party interfaces beamsoftware.com | Software departments with one of the most comprehensive coland our Stimulus Plan offer at • Free CollectOne Web Portal info@beamsoftware.com lection systems in the industry. www.collectone.com/stimulus 800-212-2326 | Web Portal • Free CollectOne legal software or call us at 888.816.3333.

BEAM™ is a suite of software for collections, recovery and • Commitment to client care Comtech Systems | Dialer purchased receivables management thatChange is available a from it. is here.as Profit Collect!• Improved bottom line hosted or on-premise solution.

Credit and Debt Collection Software collect.org CDS Software info@collect.org CollectOne Minimize costs. Maximize results.800-661-6722 collectone.com Collect! combines ease of use with total integration info@collectone.com of functions. Accounts are efficiently tracked from A CDS Software Solution 888-816-3333 the time you receive them until activity is concluded CollectOne is an award winning suite of debt coland they are closed. Collect! keeps track of critical lection solutions that provides a feature-rich set of information automatically. Total integration provides automated business processes designed to minimize for seamless and accurate month end invoices and costs and maximize results. statements with full account histories.

CODIX iMX Collection, Legal and Recovery Solution codix.us/debt_collection bquinn@codix.us 404-790-0998 iMX is a complete centralized debt collection and recovery software solution. Based on the latest technologies, iMX Debt Collection includes all the most advanced business functionalities supported by native tools.

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@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.

Comtronic Debtmaster debtmaster.com 800-414-2814 The Debtmaster® Software along with our industry leading Cloud-Hosted environment gives you a reliable, powerful, cost-effective collection solution right at your fingertips.

DAKCS Software

Systems Beyond.Net dakcs.com sales@dakcs.com 800-873-2527 DAKCS Software Systems has been an industry leader for over thirty years. Headquartered in Ogden, Utah, DAKCS provides a one stop shopping solution for a diverse client base. DAKCS is committed to providing their customer community with all the tools they need to succeed in the ever changing ARM business, today and in the future.

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.

Sentinel Development Solutions, Inc. eCollections ecollections.com sales@ecollections.com 515-564-0585 The result of 20 years of industry of industry-leading collections/recovery platform development, eCollections is a comprehensive enterprise collection system with flexible configuration, ease-of-use, powerful payment features, workflow automation, and unparalleled reporting and tracking.

Compliance LexisNexis® Risk Solutions LexisNexis ® Accurint ® for Collections lexisnexis.com/risk/receivables-management 866-528-0780 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.

Compliance Calling CallEvo CallEvo callevo.com sales@callevo.com 800-478-1084 CallEvo is the only fully compliant TCPA calling platform designed and engineered specifically to address EVERY item in the TCPA. Stop Scrubbing and Start Calling!

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Collection Support Services Applied Innovation Inc.

Client Access Web appliedinnovationinc.com sales@appliedinnovationinc.com 800-589-5651 Applied Innovation, Inc has redefined collection agency workflow with revolutionary client portal technology, document management system, and a unique “virtual collector” for online payments.

Cornerstone Support State Licensing 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.

VoApps DirectDrop Voicemail voapps.com sales@voapps.com 855-737-1596 VoApp’s patented DirectDrop Voicemail service delivers a voice message directly to a consumer’s voicemail server – without calling the phone in question.

Collection Agencies United Collection Bureau, Inc. 1st and 3rd Party Collection Services 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.

Electronic Payments

PCI Group Printing/Direct Email/ E-Delivery pcigroup.com choosepci@pcigroup.com 803-578-7700 PCI Group provides mission critical, compliant communication for the collection industry with Custom Printing, Direct Mail, E-Delivery and transparent, real-time tracking of your letters.

Predictive Dialers Noble Systems Corporation Contact Center Technology noblesystems.com info@noblesystems.com 404-851-1331

March/April 2017

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.

Noble Systems Corporation is a global leader in customer communications, providing innovative premise and cloud solutions for Contact Center, Workforce Management and Interaction Analytics technologies.

Skip Tracing IDI Inc. 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.

Innovis RPC innovis.com 855-601-1915 Innovis is a leading provider of consumer identity information. The company’s RPC solution provides collection agencies with tools to improve contact and recovery rates.

Advanced Payment LexisNexis® Risk Systems

Solutions Credit Card & Check LexisNexis ® Processing Merchant Services Accurint ® for Collections apsofga.com lexisnexis.com/risk/receivables-management jennifer@apsofga.com 866-528-0780 800-482-4561 LexisNexis Risk Solutions assist debt recovery profesAPS provides a full range of electronic payment sionals with increasing workflow efficiencies, gaining solutions, including credit, debit & HSA cards, check, greater insight into debt portfolios, collecting more in and ACH transactions, along with multiple software less time and achieving greater profitability. integration options, web payment portals, and the IKEY Product Suite with the attorney endorsed Reg E compliance solution.

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LocateSmarter Batch & Online Skip Tracing Platform www.locatesmarter.com info@locatesmarter.com 888-254-5501 LocateSmarter is a data provider focused on innovation and data quality. LocateSmarter offers skip tracing products such as phone append, bankruptcy, deceased, cell phone scrubs and more.

Mail Services

March/April 2017 Volume 16, No. 2 Editor T. Steel Rose, CPA, ACG editor@collectionadvisor.com Managing Editor Joshua Fluegel josh@collectionadvisor.com Copy Editor Myrna Nelson myrna@collectionadvisor.com Publisher Angie Rose angie@collectionadvisor.com Ad Sales Chelsea Patterson chelsea@collectionadvisor.com The opinions given by contributing authors are their own and are not necessarily the opinion of our staff and management. 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. ©2017 All Rights Reserved Magazine Publishing Group, Inc. Printed in the U.S.A.

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