Receivables Advisor January/February 2020

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Letter from the Editor

Welcome

W

elcome to 2020! With proposed more realistic collection rules floating around and the feeling of infinite possibility in the air, this year already feels like it is going to be fantastic.

Accounts receivable professionals around the country are updating compliance systems, re-evaluating their processes and considering new technology.

In November, hundreds of professionals gathered in Ft. Worth, TX to prepare for 2020 and beyond. Attendees at CollectTECH19 were greeted by the most knowledgeable presenters in accounts receivable providing in-depth information on the latest technology to better service consumers and improve their bottom line. Among the golf bays of TopGolf, professionals met, discussed challenges in accounts receivables and developed solutions. All of this was achieved in the open air and friendly sharing of information. It surely was a sight to behold. Over the next pages of this issue Receivables Advisor recaps the sights and sounds of the productive 3-day conference. Be sure to check out brief highlights of the informative presentations and peruse the top professionals, agencies and products in accounts receivables to keep an eye out for people to follow in the industry.

And of course, this issue also features columns from the leading minds in the industry. Debra Ciskey discusses concerns raised over the CFPB’s proposed Regulation F. Michael Starzec analyzes the conundrum of the CFPB declaring itself unconstitutional. Gordon Beck recaps his experience at CollectTECH19. Harry Strausser reveals recent trends in ARM education. And Ron Brown describes the closed sources for skip tracing and their importance. With selfless professionals like these providing insights, I say 2020 is the dawn of a whole new world.

Joshua Fluegel

“

You guys did a great job. A lot of buzz about this event. You can count me in next year!

– Richard J. Perr

Editor-in-Chief

josh@collectionadvisor.com

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COLLECT RECEIVABLES ADVISOR .com

January/February 2020

TECH19 1

2019

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centerpiece of CollectTECH19 was the award ceremony recognizing elite professionals and companies of the accounts receivable industry. These professionals, agencies and products push the accounts receivable industry forward to new frontiers with higher standards for compliance and business. Those searching for the future direction of the industry need only to look to the following.

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50

JANUARY/FEBRUARY 2020

RECEIVABLES PROFESSIONALS

Table of Contents

RECEIVABLES ADVISOR

COLLECT

TECH19

18

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COMPLIANCE ADVISOR

Concerns Over Email Expressed In CFPB’s Proposed Regulation F Debra Ciskey

6

MANAGEMENT ADVISOR

CollectTECH19: The Future of A/R Conferences Gordon C. Beck III

LEGAL COLLECTION ADVISOR

SKIP TRACING ADVISOR

Ron L. Brown CSI Group Director, President & CEO

Bradley T. Canter The Law Offices of Ronald S. Canter Managing Attorney

Scott Collins Action Collection Agencies, Inc. Director, Information Technology

Beth Conklin State Collection Service, Inc. Account Executive

Jacob Corlyon Capital Collection Management LLC Co-Founder & CEO

Richard G. Doane Sunrise Credit Services, Inc. President

Tracy Dudek State Collection Service, Inc. COO

Chris Dunkum First Collection Services President

Celeste Erickson TwinStar Credit Union Account Solutions Operations Supervisor

Sean Escobar USCB America SVP, Chief Administrative Officer

Mike Frost Malone Frost Martin PLLC Partner

Cindy Garner Trulliant Federal Credit Union Collections Manager

Tim Haag State Collection Service, Inc. President

Richard Haass Linebarger Goggan Blair & Sampson, LLP COO

Stefanie H. Jackman Ballard Spahr LLP Partner

Joy N. Jackson, J.D. Faber & Brand, LLC Partner

Howard George Receivables Performance Management, LLC CEO

Debra J. Ciskey Collections Coach, LLC Executive Vice President

Developing a Network of Closed Sources for Skip Tracing Ron Brown

Cash Flow is King | Frederick Wilgram Improving Collections with Text Communications Leigh Ann Lindsay Is Your Collection Software Platform “Omni-Channel Collection” Ready? | Rob Fite Waterfalling Data – Improving Success Rates for Right- Party Contact | Niki McKinnell AMCA Breach: The Tale of a Cyber Horror Story Keith Barthold Applying Automation and Artificial Intelligence

to Credit Dispute Investigation | Joe Sage

Receivables Advisor’s Awards 18

12 TRAINING ADVISOR

Bringing Your Training into Clear Focus in 2020 Harry A. Strausser III

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June D. Coleman Carlson & Messer, LLP Of Counsel

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CollectTECH19 TechTALKs 17

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Gordon C. Beck III Valor Intelligent Processing President & COO

Text and Email Collections in Technology David Kaminski, Esq. Collecting From the Unbanked and the Technology

Howard George Update on Debt Collection Related Activities From the CFPB K. (Gandhi) Eswaramoorthy Cyber-Tracking: The Surface, The Deep and Dark Web Ron Brown Technology Vendor Selection and Your Compliance Management System – Five Key Strategies Cindy Garner, Leslie Bender and Keith Bathold

Kanye West and the CFPB Michael L. Starzec

Dennis J. Barton III The Barton Law Group, LLC Owner & Managing Attorney

Joshua J. Fluegel

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Jon Balon Williams & Fudge, Inc. Vice President of Product & Innovation

Leslie Bender BCA Financial Services Chief Strategy Officer and General Counsel

1 CollectTECH19 Presentations 7

Welcome

Amy Anuk Encore Capital Group Senior Vice President, Business Development

Top 50 Receivables Professionals of the Year Top 50 Products of the Year Most Innovative Agencies of the Year

Receivables Advisor 26 Business

Directory

January/February 2020

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Compliance Advisor I Debra Ciskey

Concerns Over Email Expressed in CFPB’s Proposed Regulation F

Executive Vice President Collections Coach, LLC

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Automated Replies CA International, the Association for the Credit and Collections Industry (ACA), the The CRC urges an exemption for automated replies that Consumer Relations Consortium (CRC), and inform the sender that their email has been received. It should numerous debt collection firms called out communication seem logical that it would not be inconvenient for a consumer challenges within the proposed debt collection rule published who sends an email to a debt collector at 2:00 a.m. to receive by the CFBP earlier this year. The industry has felt stymied an automated response at 2:01 a.m. as new communication formats and technologies have Consumers have high expectations for nearly immediate flourished around them. Every other responses to their emailed inquiries. type of business has adopted emerging I have had the pleasure of responding technological channels to communicate to a consumer complaint in which The danger lies in the fact with their customers. They do not the consumer was unhappy that she have to operate under the perceived did not receive a response to her that once [an email or text is communication constraints that the Fair emailed dispute related to an item sent], the sender has no control Debt Collection Practices Act places on her credit report within 2 days, on debt collectors. Many in the debt notwithstanding the fact that the Fair over when the email actually collection industry have decried the Credit Reporting Act allows a data “solutions” provided by the CFPB as furnisher 30 days to investigate and transmits. Potentially setting up uninformed, unworkable, and stemming respond to a direct dispute from from antiquated thinking. Technology the consumer. debt collectors for inadvertent vendors serving the collection industry According to a study conducted violations. Easy to defend? are contemplating ways to help their in 2018 by Jeff Toister, CPLP, of customers comply with the proposed Toister Performance Solutions, “A Maybe, but the associated requirements, while industry members one-hour email response time will are taking a “wait and see” approach, meet the expectations of 89% of your expense could create another awaiting the final adoption of the customers. Companies aiming for rule. Let’s take a look at a few of the world-class customer service should potential risk that isn’t worth it proposals and industry comments. respond within 15 minutes or less.” for a debt collector working in a (https://www.toistersolutions.com/ Time of Day blog/2018/4/15/how-fast-shouldstrict liability environment.

ACA raised serious concerns related a-business-respond-to-an-email, to constraints in the rule around the accessed on 10/8/2019.) delivery of email and text messages As this study demonstrates, the at inconvenient times for the consumer, determined from time restriction on emails could impact consumer satisfaction the time the communication is sent. The danger lies in the with debt collectors’ handling of consumer electronic fact that once the send command is activated, the sender correspondence. It also does not account for the fact that has no control over when the email actually transmits. a debt collector may have partners on the other side of the There are so many stops along the way over which the world who may be tasked with investigating and sender has no control that can delay the transmission of an responding to consumer disputes received via email. The email, potentially setting up debt collectors for inadvertent time-based restrictions for electronic communication violations. Easy to defend? Maybe, but the associated expense needlessly build inconvenience and consumer dissatisfaction could create another potential risk that isn’t worth it for a into a process that is meant to reduce consumer debt collector working in a strict liability environment. inconvenience.

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January/February 2020

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Agency Advisor I Gordon C. Beck III

CollectTECH19: The Future of A/R Conferences

I

have had the opportunity to participate in over 200 conferences in my 22 years in the industry, each with its own unique qualities and benefits to speak of. Some conferences are great for content, others for networking, some big, some small and a few that are exclusive. Participating in the industry is valuable no matter what the conference, but over the years and with more and more conferences beckoning our attendance, it has become increasingly difficult to determine which conferences to budget for and which ones to pass on. The similarities of the conferences are striking and can, in most cases, only be distinguished by the attendee list and venue. That is however, until now.

I had the extreme honor of being the opening keynote speaker and master of ceremonies for this year’s newly established CollectTECH19 conference in Ft. Worth, Texas during the third week of November. Without bias, I can tell you this conference was different in many refreshing ways.

These are not just my thoughts and opinions, these are the sentiments of dozens of professionals that I had the pleasure of speaking with before, during and after the conference and I will share those sentiments throughout this article for those that were unable to attend.

Involved

For starters, the participation was second to none. Many conference attendees don’t understand or realize just how much preparation goes into the conference and the sessions. Not only is it a massive undertaking for those that are choreographing the conference, but it takes a great deal of “guts” for the presenters putting together valuable Information for the crowd.

At many conferences, while those brave souls are on stage sharing their knowledge, the halls and foyers outside of the conference room are packed with attendees on their phones, laptops and tables doing what they could be doing right back in their offices. At CollectTECH19, this was not the case.

Whether it was during the sessions, the receptions or the special events, the attendees were engaged, involved and participating right up to the last minute on the last day of the conference. To say this was “refreshing” is a true understatement. Technology is critical to the futures of almost all of the A/R organizations in America and it showed.

The Layout

The conference layout was genius. The first day opened

6

President/COO Valor Intelligent Processing

with the keynote, followed by two great tech presentations that included five AI/machine learning organizations and brought so much to light on this new technology and how it is utilized throughout the industry. This flowed right into the opening reception which kept the group together; and by starting the conference at 2:00, it allowed the participants an opportunity to arrive that morning and save them an extra night’s stay.

The next day was truly epic and well thought out. Buses picked everyone up at 8:00 a.m. and shuttled the group to Top Golf for a great breakfast as the technology vendors set up in the golf bays to display their products and materials. The day was filled with incredible presentations by industry experts in the conference area and the schedule was broken up with golf, tech demos and networking all day long. Again, everyone was in the same place at the same time and participating, learning and, most importantly, having a great time. The day flew by and was highlighted by an amazing awards presentation at the end of the evening where the top collection professionals and top tech companies were honored and recognized for their incredible impact on the industry.

The last day started with breakfast while I had the pleasure of having a “fireside” chat with John McNamara of the CFPB. As always, John did not disappoint as his insight and knowledge of the Bureau and our industry is second to none. The conference concluded with a bang as every technology company was present for the industry’s largestever technology round robin, the TECHtalk Roundtables.

Each attendee got to choose five, twenty-minute round tables with any technology provider they wanted to learn more about. It was incredible to see everyone stay and participate even though the conference let out at noon. The amount of information available and the amount of knowledge gathered undoubtedly sent every company home with a greater understanding of what they truly want to do with their organization’s future technological advances, but more importantly, put them on a path to get there.

From the participation, incredible speakers, transparency of the industry professionals sharing best practices, conference layout, Top Golf day and awards and the incredible number of tech companies in attendance assisting the agencies in their technological needs, this conference stands alone on so many levels and is undoubtedly one that you won’t want to miss in 2020!

January/February 2020

RECEIVABLES ADVISOR .com

CollectTECH19 | Presentations

Cutting Edge Education for 2020

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ttendees of CollectTECH19 came from all over the nation with one common goal: Find the latest technology and tactics to increase their ROI and compliance.

Presenters brought their vast knowledge of collection tools to reveal exactly what professionals can do tomorrow to find success using technology available today. The following are excerpts from some of the in-depth presentations at CollectTECH19.

Kaminski: Text and Email - 7 George: Collecting from Unbanked - 9 Eswaramoorthy: CFPB Update - 11 Brown: Cybertracking - 13 Bender: Technology Selection - 15

Text and Email Collections in Technology David Kaminski, Esq. Partner | Carlson & Messer LLP

Misconceptions and Misunderstandings about Digital Communications

• A text message is writing that triggers state writing requirements.

• Keyword programs are subject to allowable call-time restrictions.

• Pass-through consent from original creditor is risk-free • Human intervention is the only requirement to launch a manual call.

• Text messages do not count against your frequency of calls policy.

• E-Sign does not apply to the ARM industry.

Requirements: Consent to Text Companies may obtain verbal consent

for non-telemarketing voice and text calls to wireless numbers made using an automatic telephone dialing. Consumers must simply give their mobile Continued on page 9

Legal Collection Advisor I Michael L. Starzec

Kanye West and the CFPB

Partner Blitt and Gaines, P.C Vice-president Illinois Creditors Bar

A

mericans always love a redemption story, CFPB’s single director, removable only for “inefficiency, especially where the party seeking forgiveness neglect of duty or malfeasance” violated the separation of is a celebrity. For example, to this day, Kanye powers of the Constitution. Surprisingly, the DOJ filed West is vilified for stepping on Taylor Swift’s moment at a brief in support of the writ, arguing that the President the 2009 MTV Video Music Awards. Notwithstanding, is constitutionally bound to ensure the laws are faithfully recently, despite having married a woman who became executed, so that the President’s abilities to appoint, oversee famous under the worst of circumstances, Kanye has literally and remove executive officials were all essential to fulfill found religion, leading revival meetings around the nation that duty. The brief also disagreed with the lower court’s and having expressed contrition to the Swifties. As a sure finding that the CFPB’s structure was analogous to that of sign of his sincerity, he has even the FTC because both the FTC and suggested Kim dress less suggestively, CFPB directors were removable for which surely cuts against their bottomcause. According to the DOJ, the line. Now, if you are wondering how CFPB, prosecutes and investigates, “Keeping Up with the Kardashians” i.e. executive powers, while the intersects with collections, you need FTC is a board with quasi-legislative Will the CFPB now rely on only refer to a Justice Department and judicial powers, with staggered brief, ostensibly filed on behalf of the terms, assuring a more bi-partisan, input of both creditor and CFPB, where the CFPB declared collaborative policymaking body. itself unconstitutional.

Staggered terms allow Presidential appointment to the FTC which consumer advocates?

CFPB Declares Itself Unconstitutional? contrasts with the CFPB whose This admission against interest was director actually serves longer than a Hardly. As always, the greeted with a range of emotions in President, shielding them from the the collection universe, from mocking electorate. devil is in the details.

“I-told-you-sos” to utter relief. So is this a Kanye redemption moment?

Part May Remain Has the CFPB repented of its extraHowever, the CFPB’s end is constitutional powers? Have they not nigh. The Credit Card admitted wrongdoing in seeking Accountability Responsibility liability for actions never determined and Disclosure Act (CARD Act), illegal? More importantly, will the CFPB now rely on input consistent with precedent, explicitly allows that if one part of both creditor and consumer advocates? were found unconstitutional, the remainder of the Act Hardly. As always, the devil is in the details. would survive. Importantly, the brief did not question that Having read the decision, the CFPB is not advocating CIDs were constitutional because Congress can delegate its to decommission itself like an unwanted nuclear reactor. subpoena powers.

In reality, it suggests a modified version of the Queen of And with all things collection related, there are Hearts from “Alice in Wonderland” combined with the politics: If the Supremes agree, they punt to Congress Hydra – off with its head – and then replace the single to rewrite the Act. Who among us thinks the Democrats head with several more. and Republicans are going to agree, in an election year,

It all started when a collection firm sought writ on the CFPB’s structure and let Trump appoint the first of certiorari to the U.S. Supreme Court appealing a lower commissioners? Even more, imagine if Elizabeth Warren, court’s finding the CFPB’s structure constitutional, thereby from whose mind the CFPB erupted, is the President when allowing the CFPB’s Civil Investigative Demand (CID) Congress considers changes? All I can say to that is this: against the firm to proceed. The firm had argued that the Kanye 2024!

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January/February 2020

RECEIVABLES ADVISOR .com

CollectTECH19 | Presentations Text and Email Collections in Technology Continued from page 7 number to the texting party or its agent [creditor/provider or its first-or third-party agency]. This type of consent does not activate the automated text platform.

Content Requirements Per Text

• The name of texting party/ company.

• This is a communication from a debt collector [FDCPA and state law may require this of both the third party, first party, and creditor].

• Text and Message rates may apply [only in initial].

• 160 – 900 character restrictions [This includes letters, punctuation and spaces]. Limiting text to 160 characters per text will prevent the message from being broken into parts by the carriers.

• Abbreviations must be defined.

• Confirmation of stop is required

by CTIA [Cellular Telecommunication Industry Association].

• Daily scrub of ported and deactivated mobile numbers.

• A terms and Conditions document.

Text Messaging for Third-Party Collections – Terms & Conditions

Ensure your text message program complies with disclosure requirements of the FDCPA. Company initiated texts are communications in connection with the collection of a debt under current law: • Full mini-Miranda if the text is the first communication with the consumer [“This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose.”]

• Subsequent disclosure requirement [“This is a communication from a debt collector,”] if the text is not the first communication with the consumer.

Collecting From the Unbanked and the Technology Howard George CEO | Receivables Performance Management, LLC In 2017, 6.5% of U.S. households were “unbanked,” meaning that no one in the household had a checking or savings account. An additional 18.7% of U.S. households were “underbanked” in 2017, meaning that the household had an account at an insured institution but also obtained financial products or services outside of the banking system.

Almost 70% (68.4%) of U.S. households were “fully banked” in 2017, meaning that the household had a bank account and did not use alternate financial services (AFS) in the past 12 months. The fully banked rate in 2017 was slightly higher than the 2015 estimate (68%).

More than half (52.7%) of unbanked households cited “Do not have enough money to keep in an account” as a reason for not having an account, the most commonly cited reason.

Almost one-third (30.2%) of

unbanked households cited “Don’t trust banks” as a reason for not having an account, the second-most commonly cited reason. (This reason was also the second-most commonly cited main reason (12.6%)).

As in previous years, higher proportions of unbanked households that previously had an account cited “Bank account fees are too high” (29.9%) or “Bank account fees are unpredictable” (24.9%) in 2017, compared with unbanked households that never had an account (21.1 and 17.0%, respectively).

Payment Channels to Consider When Collecting From the Unbanked • PayNearMe • Payday Loans • Cardpool • Google Pay

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Skip Tracing Advisor I Ron Brown

Developing a Network of Closed Sources for Skip Tracing

A

Member National Association of Fraud Investigators Author “MANHUNT: The Book” Contact rbrown2150@aol.com

s we begin this article it is very important that the professional tracer clearly understand what constitutes a “closed source,” its value and the obligation due to each closed source. By definition a closed source is a source of information with restricted access and information available only through mutual information sharing agreements. To clarify the definition as it applies to the tracing industry, a source of information available to the tracer and not to the general public built on mutual trust and confidence.

system, if someone would gain access to your contact list, they would not be able to readily access your information.

Record of Payment: If there is any type of payment for the information, which by the way is a business tax deduction, I suggest a record showing the date, amount and method of payment. I caution the tracer to never pay for information in violation of any municipal, state or federal law. And never ask the source to violate any law.

Why Use a Closed Source? Every tracer must have a closed source

residence and employment of John Smith. I cyber track to check chattel mortgage records (usually filed with the Secretary of State) in the state where I suspect John Smith resides and locate the lien filing on his vehicle, a 2019 Ford F150 truck. The lien filing provides the vehicle identification number of the vehicle (F150XXXYYYZZZ).

network, a person or place that will provide information to the tracer and to no one else. Developing and expanding their closed source network is a fundamental requirement if the tracer is to be successful. These closed sources must have an absolute and complete trust in the tracer. They must know for certain the information they provide will be used in a legal manner and the tracer will never disclose the source of the information. In many cases the exchange of information may flow in both directions.

There may be in some cases some other types of remuneration to the source for providing the requested information.

Closed Source Communication I would first suggest that tracer

decide how to protect the network “in transit.” It is my opinion the best way to preserve the closed source network contact information is through the utilization of a dedicated thumb drive. This method provides a mobile source, easy to transport, available from any computer and password protected.

The data on the thumb drive list should contain the following information on each individual source: Name: I would suggest the tracer never put the sources real name down but rather use a code name or number. For example, 19-101 or EMPNFO -19. The significance of the 19 would be the year indicator enabling the tracer to know at a glance how current the source might be. The EMPNFO would indicate the source had employment information.

Contact Information: If the tracer is using a telephone number to contact the source, I suggest the number be coded. I often use CANDYSTORE, where C = 0, A = 1 N = 2 and so on until E = 9. Alternatively, I also use a crisscross variation of the phone key pad where 1 = 9 and 9 = 1, 3 = 7 and 7 = 3, 4 = 6 and 6 = 4, 2 = 8 and 8 = 2 and finally 5 = 0 and 0 = 5. By using this coded

10

How a Closed Source Works Let’s say I am trying to locate the

I now move from cyber tracking mode to skip tracing mode and contact my closed source of information, the Finance and Insurance Manager at the local Ford dealership. I provide him the VIN to the vehicle and he runs it through his international database. Since the vehicle is under warranty, it will indicate the last time the vehicle was serviced, where it was serviced, the address provided the dealership and the daytime contact number (usually the employment number). Now I move back to the cyber tracker mode and run the daytime phone number which will provide the consumer’s employment address, I run motor vehicle records to obtain the tag number of the vehicle which I place in an LPR system and finally check out the residence address provided to the dealership by using Google Earth to determine the consumers life style.

By using a combination of cyber tracking and skip tracing through a closed source of information, I have current location information on my missing consumer.

I once had a tracer tell me they had no closed sources, no one they could go to get information. I asked if they had brothers or sisters. The reply was, “yes.” I asked where they were employed.

The brother was a deputy sheriff and his wife worked for the city utility department, the sister worked at the local library and her husband was employed in the service department at a local truck dealership. What a closed source network to have at her fingertips.

The closed source network, another tool in the professional tracer’s tool bag. Good luck and good hunting.

January/February 2020

RECEIVABLES ADVISOR .com

CollectTECH19 | Presentations Update on Debt Collection Related Activities From the CFPB K. (Gandhi) Eswaramoorthy Program Manager for Debt Collections | Consumer Financial Protection Bureau

Eswaramoorthy of the CFPB provided statistics on recent trends in the industry as well as updates on current rulemakings. [See below]

Debt Collection Rulemaking

The Bureau was originally considering a debt collection rulemaking for third-party debt collectors that would focus on three primary goals: 1) Make sure collectors are contacting the right consumer and collecting the right amount, 2) Make sure that consumers understand the debt collection process and their rights, 3) Make sure consumers are treated with dignity and respect.

After considering feedback, the Bureau determined that the “right consumer, right amount” issues would be best pursued in a later rulemaking that included requirements for creditors and third-party collectors. But, those collecting on the debts do need to have correct and accurate information.

The Bureau’s proposed NPRM rulemaking covers FDCPA-

defined third-party debt collectors that addresses the latter two issues.

If finalized, the NPRM would: 1. Provide a bright-line rule that would prohibit, with certain exceptions, a collector from placing more than seven unanswered telephone calls to a person within a seven-day period about a particular debt, and from calling a person within seven days after the collector has engaged the person in a telephone conversation.

2. Provide that a voicemail or text message that contains only specified required and optional content is not a communication under the FDCPA. 3. Clarify that consumers may designate a time or place as inconvenient for communication.

Continued on page 13

Levels of consumer debt delinquency rates + DPD) rising are risin Levels of consumer debt and delinquency rates (90are + DPD) Levels of consumer debt andand delinquency rates (90(90 + DPD) are rising NON-HOUSING CONSUMER DEBT PERCENT OF NON-HOUSING BALANCES 90+ NON-HOUSING CONSUMER DEBT PERCENT OF NON-HOUSING BALANCES 90+ NON-HOUSING DEBT2003–2018 PERCENT NON-HOUSING BALANCES BALANCES CONSUMER (IN TRILLIONS), Q4 DAYSOF DELINQUENT, 2003-2018 Q4 90+ BALANCES (IN TRILLIONS), 2003–2018 Q4 DAYS DELINQUENT, 2003-2018 Q4 BALANCES (IN TRILLIONS), 2003–2018 Q4 DAYS DELINQUENT, 2003-2018 Q4

3.0 2.5 2.0 1.5 1.0 0.5 0.0

3.5 3.0 2.5 2.0 1.5 1.0 0.5 0.0

4.5

16%

4.0

14%

3.5

12% 10%

3.0 2.5 2.0 1.5

Other

16%

14%

14%

12%

12%

10%

10%

8% 8% Other 6% 6% Student Loan

Other

Student Loan Student Loan Credit Card Credit Card Auto Loan Auto Loan

4% 2%

1.0

0%

0.5 0.0

16%

4% Card Credit Auto Loan 2% 0%

8% 6% 4% 2% 0%

03:Q1 03:Q4 04:Q3 03:Q1 05:Q2 03:Q4 06:Q1 04:Q3 06:Q4 05:Q2 07:Q3 06:Q1 08:Q2 06:Q4 09:Q1 07:Q3 09:Q4 08:Q2 10:Q3 09:Q1 11:Q2 09:Q4 03:Q1 12:Q1 10:Q3 03:Q4 12:Q4 11:Q2 04:Q3 13:Q3 12:Q1 05:Q2 14:Q2 12:Q4 06:Q1 15:Q1 13:Q3 06:Q4 15:Q4 14:Q2 07:Q3 16:Q3 15:Q1 08:Q2 17:Q2 15:Q4 09:Q1 18:Q1 16:Q3 09:Q4 18:Q4 17:Q2 10:Q3 18:Q1 11:Q2 18:Q4 12:Q1 12:Q4 13:Q3 14:Q2 15:Q1 15:Q4 16:Q3 17:Q2 18:Q1 18:Q4

3.5

4.0

10:Q1 11:Q1 12:Q1 13:Q1 14:Q1 15:Q1 16:Q1 17:Q1 18:Q1

4.0

4.5

03:Q1 04:Q1 05:Q1 03:Q1 06:Q1 04:Q1 07:Q1 05:Q1 08:Q1 06:Q1 09:Q1 07:Q1 10:Q1 08:Q1 11:Q1 09:Q1 12:Q1 10:Q1 13:Q1 11:Q1 14:Q1 12:Q1 03:Q1 15:Q1 13:Q1 04:Q1 16:Q1 14:Q1 05:Q1 17:Q1 15:Q1 06:Q1 18:Q1 16:Q1 07:Q1 17:Q1 08:Q1 18:Q1 09:Q1

4.5

Auto loans Credit cards Auto loans Credit cardsAuto loans Student loans Other Student loans Student loans Other

Credit cards Other

Source: FRBNY Consumer Credit Panel/Equifax.

Source: FRBNY Consumer Credit Panel/Equifax.

Source: FRBNY Consumer Credit Panel/Equifax.

RECEIVABLES ADVISOR .com

January/February 2020

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Benchmark Advisor I Harry A. Strausser III

Bringing Your Training into Clear Focus in 2020

W

Director of Education and Membership Development ACA International, Inc. Contact strausser@ acainternational.org

e are off to a new decade in the ARM embrace an omni-channel culture we will see more movement industry and there is no doubt that it in this direction. will be a time of continued change and adjustment for everyone in the credit and collection Situational Training Opportunities market. What will be important as we move forward is to We often place much training focus on developing develop plans, strategies and cultures that will embrace educational “programs and classes” but there are a multitude this new era. Rules are changing. Regulations continue of situational opportunities to teach approaches, policies, to develop on state and federal procedures and compliance. platforms. Technologies will emerge Overhearing a call, reviewing call and become commonplace in our recordings and general collection floor We don’t have to produce perfect offices; technologies that will enhance questions are training opportunities. our communication and place pressure It is training on the fly! training in our organizations, on all organizations, regardless of size, but we do have to possess to adopt these new alternatives. No Micro-Training Opportunities matter what you are doing now, you In the same theme as the situational clarity about what is important will have to enter this new time with a training, not all education has to very clear vision of your direction. be offered in large chunks, an hour to the success of our staff and In a recent blog I read, “When or two at a time. Create very short, most people hear the term 20/20 vision concise training opportunities for organization overall. or find out they have 20/20 vision, your staff. Get the point across they understand that to mean that they quickly about a valuable topic and do have perfect vision…but 20/20 vision does not mean having this regularly in between other longer classes. Put some short ‘perfect vision.’” It goes on to state, “When the optometrist classes on your internal learning management system. This says that you have ‘20/20 vision’ he is referring to your visual plan keeps the momentum rolling on your team! acuity, which is the clarity or sharpness of your vision.” We don’t have to produce perfect training in our organizations, Get started early in 2020 with defining your vision! I am but we do have to possess clarity about what is important to reminded of the popular lyrics by Johnny Nash: the success of our staff and organization overall. How will you I can see clearly now the rain is gone change your training in this new decade and what resources I can see all obstacles in my way will you tap into to do so?

Gone are the dark clouds that had me blind Here are a few trends that are taking place in ARM It’s gonna be a bright (bright) industry workplace education: Bright (bright) sunshiny day!

Shifts From Compliance Focus to Tactics and Techniques

Compliance is certainly critical in all collection operations.

We tend to spend a tremendous amount of resources on compliance topics. Many trainers are addressing only the compliance components that apply to the functions of the front-line collector and leaving the heavier topics to management programs. There is a new direction today related to working on communication and soft skills as we create new models of consumer interactions. And as organizations

12

May your 2020 be bright, productive and at yearend you can reflect on your clear direction and training accomplishments!

We continually welcome thoughts and best practices from our readers. Feel free to send us your feedback for possible inclusion in a future column. Until next time, I’m at my ACA office waiting to hear from you!

Harry can be reached at Strausser@acainternational.org or at 570-336-7056.

RECEIVABLES ADVISOR

CollectTECH19 | Presentations Update on Debt Collection Related Activities From the CFPB Continued from page 11 4. Clarify that consumers may request that a collector not use a specific medium (e.g., email, phone calls, or phone calls to a particular telephone number) for communication; further communication using that medium (with some exceptions) would be prohibited.

5. Clarify that calls to mobile telephones and electronic communications, such as texts and emails, are subject to the FDCPA’s prohibition on communicating at unusual and inconvenient times and places.

6. Require collectors to include in all electronic communications instructions for opting out of further such communications to a particular email address or telephone number.

7. Prohibit collectors from (with some exceptions) using an email address that the collector knows or should know is provided by the consumer’s employer and from contacting consumers using public-facing social media platforms.

The NPRM would propose to identify procedures that, when followed, would provide a safe harbor from liability for collectors who, when communicating with a consumer by email or text message, unintentionally communicate with third parties about a debt.

A collector would be entitled to the safe harbor if, among other things, it communicated with the consumer electronically using: 1. An email address or telephone number that the consumer recently used to contact the collector for purposes other than opting out of electronic communications; 2. A non-work email address or non-work telephone number if the consumer first received notice and an opportunity to opt out of electronic communications to that address or number but did not opt out; or 3. A non-work email address or non-work telephone number obtained by the creditor or a prior collector from the consumer and recently used by the creditor or a prior collector to communicate about the debt, as long as the consumer did not ask the creditor or prior collector to stop using that email address or telephone number.

Cyber-Tracking: The Surface, The Deep and Dark Web Ron Brown Owner ConSec Investigations, Inc. Here are some great sites for monitoring social medial in search for a consumer:

Technorati Technorati is the largest blog monitoring

service. Once you register your blog on Technorati, it tracks any blogs that reference your posts. To sign up for alerts, just search for your blog, then subscribe to the RSS feed.

Addictomatic Addictomatic allows you to create a

personalized tracking page and pulls content from all over the Internet including, but not limited to Google, Yahoo, Technorati, YouTube, Truveo, Flickr, Blinkx, Ice Rocket, Digg, Topix, Newsvine and Tweetscan. Addictomatic is incredibly easy to use: Step 1: Enter a keyword to track.

Step 2: Modify the boxes—add or subtract places you want content pulled from.

Step 3: Bookmark it and check back.

Twazzup While I hate to mention anything with such a

terrible name, Twazzup is a useful tool.

Enter a keyword and Twazzup creates a dashboard tracking that keyword on Twitter. It breaks down and categorizes by link popularity, contributors, news, tag clouds and users, along with and including photos. It also shows who said what, how many times something was said, and how influential are the people saying it.

BoardTracker With BoardTracker, you can set up keywords to track, choose your preferences, and have the results emailed to you. It allows you to run searches on topics/keywords that are being discussed in forums or discussion boards.

The great thing about BoardTracker is that it can tell you who is contributing to which topics and ranks them in order of frequency.

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RECEIVABLES ADVISOR

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TECH19

“

I loved the format of the golfing with lunch and time with the vendors. It was fun and informal and provided a lot of time with the vendors. I also liked that the sessions were short and sweet.

– John Myers

“

John McNamara and Richard Perr

I was unsure of the venue (TopGolf) but once people got the hang of it, visiting the “Booths” was fun.

– Jeff Hobbs

Temitayo Harriman

“

Mike Frost, Debra Ciskey and Rick Perr provide tech solutions to upcoming regulation.

Relaxed environment that allowed for great interaction.

– Connie Matrisch

Aaron J. Newell

“ Angie Rose, Steel Rose, Michael Lamm & Steven Kusic

Original and entertaining use of a venue - creative manner of discussing topics.

Informational as well.

– John Chotkowski

January/February 2020

RECEIVABLES ADVISOR .com

CollectTECH19 | Presentations

Technology Vendor Selection and Your Compliance Management System – Five Key Strategies Leslie Bender CIPP/US, CCCO, CCCA, IFCCE Chief Strategy Officer and General Counsel BCA Financial Services Cindy Garner Collections Manager Truliant Federal Credit Union Keith Bathold CEO | DKBinnovative Highlighted here are several important strategies the vendor selection component of your compliance management system should include when onboarding a new technology or new technology vendor. Any organization’s compliance management system is a living, breathing and dynamic series of tactics or strategies by which your organization assures it has adequate safeguards and controls in place to achieve its objectives in accord with the law and in a manner that delights its customers. Here are some practical insights into both a creditor’s and a vendor’s perspective on topics.

Re-Evaluating Pre-and Post-Selection Due Diligence Tactics

From the creditor’s perspective: Is the vendor living up to the representations it made about its compliance management system in

response to requests for proposals or other vendor engagement efforts?

From the vendor’s perspective: • Is the creditor’s work placed consistent with what the vendor expected?

• Does the vendor have sufficient controls and resources to live up to the standards it stated it had in the materials it proposed or provided that led to the creditor selecting it?

• Are all technologies working properly and aligning to the creditor’s expectations?

Key Contract Terms

Litigation has shown that a few minor updates to your standard contract provisions can position you to improve communication over technology resources.

Suggestions: • Encouraging creditor to obtain “consents” from consumers when the original debt is incurred or services are rendered to allow all the parties to use all forms of communication technology available to interact with the consumer.

• Reciprocal commitments to notify each other in the event of a security incident or other major non conformity with any compliance standard.

Leslie Bender

Cindy Garner

Keith Barthold

Gordon Beck opens the conference with an AI Town Hall with Erin Stewart, Kate Bakewell, Gregory Allen, Trip Edwards and Harris Kirkpatrick

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January/February 2020

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“

TECH19

The focus on tech was very appealing.

–John McNamara

Perfect weather for a drive.

“

Temitayo Harriman (center), Ray Peloso (right)

“

The sessions were based on content, not product.

We focused on problems and solution ideas instead of pointing directly to a vendor and stating “they have something to handle this.

– Brian Sharp

The vendors were more a part of the conference. There was plenty of opportunities to speak with vendors in a more informal capacity.

– Attendee

“

Congrats on pulling off a great conference.

– Trip Edwards

Ding dong...

Paul Maggiolo

“

Ron Brown

We are greatly looking forward to next year! – Brittan Adams

...a beer for you.

Jack Snitkovsky & Neal Jagoda

Future Tech Tactics

H

undreds of professionals gathered on the final day of CollectTECH19 to discuss numerous topics at the TECH talk Roundtables. With 30 discussion topics ranging from text and email communication to waterfalling data, professionals rotated tables and discussions every 25 minutes ensuring everyone was fortified with knowledge to make 2020 their best year ever.

Here is a glimpse into some of the topics discussed.

Cash Flow is King

Frederick Wilgram | Global Director of Strategic Alliances at PlugNPay In the early days of merchant processing, merchants received their deposits in seven days providing acquiring banks to profit off the money they held and severely curtailing merchants’ ability to control their cash flow. As the years went by competitive pressure forced the processors and acquiring banks to accelerate the settlement process, first to five, then three, two and now “next day”. Anybody running a business knows that cash flow is king.

While “next day” funding is good, it is not good enough.

Thankfully the next step is now available, Instant Merchant Settlement.

Several years ago a group of bankers and financial experts began to formulate a way to accelerate cash flow by creating instant merchant settlement (IMS). Now, a merchant can batch out and one second later, all their processing funds are in their bank account 24/7 including holidays.

Many industries will take advantage of IMS. One industry that is prime to take advantage is the collections industry. For agencies having gross remittance clients, IMS allows the agency to use their daily batch funds to fund their clients rather than front the funds. PlugNPay, established in 1996 is the oldest payment gateway in the US, prides itself as being on the cutting edge of technology. PlugNRon Bonavita and Joe Pay and its financial Sage engage the partners are pleased table discussing the to offer IMS to the collections newest technologies industry. for credit disputes.

PlugNPay can be integrated into any collection management software.

It’s your money. Why wait for it.

TECHtalk Roundtables

Improving Collections with Text Communications Leigh Ann Lindsay VP of Client Relations at Solutions by Text By 2020, nearly 49 million people will opt in to receive text messages from businesses. That figure has grown by 31% since 2016. In fact, 9 out of 10 consumers want to use text messaging to interact with businesses. Are you communicating with your consumers the way they prefer?

Consent is the Key When communicating with consumers, ob-

taining consent is key. There are laws and regulations that dictate that companies are required to obtain consent before sending a text message to a consumer. Great news is Solutions by Text has all the tools to keep you compliant every step of the way.

The World is Changing Digital communication is becoming more prevalent with businesses. Text messaging is the most frequently used application on consumers’ smartphones today. There are more than 6 billion text messages sent in the United States every day in the United States. Three out of four consumers reported they were upset that they could not reply via text message. Twoway texting offers the opportunity to equip your representatives with a tool that will yield results.

Watching the Bottom Line An impactful call-to-action is key to

a successful campaign. Branded links, or shortened links built around a brand name, have a 39% higher click-through rate than generic URLs. Smart Click provides a unique opportunity for customers to self-serve via payment portal, text pay or website.

It also has trackable shortened URLs, either via SBT’s {sclk.me} domain or via a custom domain, which allows you to see what is happening and optimize accordingly.

Solutions by Text offers a wide variety of products and services to send the perfect message at the perfect time.

Is Your Collection Software Platform “Omni-Channel Collection” Ready?

Rob Fite | VP of Business Development and Marketing at Telrock Three out of every five existing collection platforms in use today have become a hindrance to their collection organization. The reason being, these software platforms have become outmoded, and do not provide the broad and rich set of capabilities needed for how collections operations want and need to collect today.

This is especially true for collection operations that want to take an “Omni-Channel Collection” approach. In other words, Continued on page 23

2019

TOP

50

RECEIVABLES PROFESSIONALS

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TECH19

A

centerpiece of CollectTECH19 was the award ceremony recognizing elite professionals and companies of the accounts receivable industry. These professionals, agencies and products push the accounts receivable industry forward to new frontiers with higher standards for compliance and business. Those searching for the future direction of the industry need only to look to the following.

Amy Anuk Encore Capital Group Senior Vice President, Business Development

Jon Balon Williams & Fudge, Inc. Vice President of Product & Innovation

Dennis J. Barton III The Barton Law Group, LLC Owner & Managing Attorney

Gordon C. Beck III Valor Intelligent Processing President & COO

Leslie Bender BCA Financial Services Chief Strategy Officer and General Counsel

Ron L. Brown CSI Group Director, President & CEO

Bradley T. Canter The Law Offices of Ronald S. Canter Managing Attorney

Scott Collins Action Collection Agencies, Inc. Director, Information Technology

Beth Conklin State Collection Service, Inc. Account Executive

Jacob Corlyon Capital Collection Management LLC Co-Founder & CEO

Richard G. Doane Sunrise Credit Services, Inc. President

Tracy Dudek State Collection Service, Inc. COO

Chris Dunkum First Collection Services President

Celeste Erickson TwinStar Credit Union Account Solutions Operations Supervisor

Sean Escobar USCB America SVP, Chief Administrative Officer

Mike Frost Malone Frost Martin PLLC Partner

Cindy Garner Trulliant Federal Credit Union Collections Manager

Howard George Receivables Performance Management, LLC CEO

Tim Haag State Collection Service, Inc. President

Richard Haass Linebarger Goggan Blair & Sampson, LLP COO

Stefanie H. Jackman Ballard Spahr LLP Partner

Joy N. Jackson, J.D. Faber & Brand, LLC Partner

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Debra J. Ciskey Collections Coach, LLC Executive Vice President

June D. Coleman Carlson & Messer, LLP Of Counsel

TOP 50

RECEIVABLES PROFESSIONAL OF THE YEAR

Receivables Professionals of the Year

LaDonna Bohling

Receivable Solutions, Inc. Chief Compliance Officer

David J. Kaminski, Esq. Carlson & Messer LLP Partner

Craig W. Klein Capital Recovery Systems President

Michael Klutho Bassford Remele Shareholder/Attorney

Steven Kusic National Recovery Agency CEO

Aaron J. Newell AR Solutions Inc. President/CEO

Richard J. Perr, Esq. Fineman Krekstein & Harris, P.C. Partner

Kim Phan Ballard Spahr LLP Partner

Courtney Reynaud Creditors Bureau USA President

Jim Richards Capio Partners Chairman

Michael Ryalls RGS Financial Chief Strategy Officer

Jeffrey S. Simendinger SIMM Associates Co-Founder & COO

Lauren Valenzuela, Esq. Performant Recovery, Inc. Compliance Counsel

Joe Adams Hampton Prior Group Inc. Amy Anuk Encore Capital Group Jon Balon Williams & Fudge, Inc. Dennis J. Barton III The Barton Law Group, LLC Gordon C. Beck III Valor Intelligent Processing John H. Bedard, Jr. Bedard Law Group, P.C. Leslie Bender BCA Financial Services LaDonna Bohling Receivable Solutions, Inc. Ron L. Brown CSI Group George Buck Frost-Arnett Bradley T. Canter The Law Offices of Ronald S Canter Debra J. Ciskey Collections Coach, LLC June D. Coleman Carlson & Messer, LLP Scott Collins Action Collection Agencies, Inc. Beth Conklin State Collection Service, Inc. Jacob Corlyon Capital Collection Management LLC Jeff DiMatteo American Profit Recovery Richard G. Doane Sunrise Credit Services, Inc. Kaye M. Dreifuerst Security Credit Services, LLC Tracy Dudek State Collection Service, Inc Chris Dunkum First Collection Services Celeste Erickson TwinStar Credit Union Sean Escobar USCB America Mike Frost Malone Frost Martin PLLC Cindy Garner Trulliant Federal Credit Union Howard George Receivables Performance Management Tim Haag State Collection Service, Inc Richard Haass Linebarger Goggan Blair & Sampson, LLP Stefanie H. Jackman Ballard Spahr LLP Joy N. Jackson, J.D. Faber & Brand, LLC David Kaminski, Esq. Carlson & Messer LLP Craig W. Klein Capital Recovery Systems Michael Klutho Bassford Remele Steven Kusic NRA Group Robbie Malone Malone Frost Martin John McNamara Consumer Financial Protection Bureau Steve Neumann Marine Credit Union Aaron Newell AR Solutions Inc. Tom Penaluna CBE Companies, Inc. Richard J. Perr, Esq. Fineman Krekstein & Harris, P.C. Kim Phan Ballard Spahr LLP Courtney Reynaud Creditors Bureau USA Jim Richards Capio Partners Jeremy Ruth Arvest Bank Michael Ryalls RGS Financial Jeffrey S. Simendinger SIMM Associates Michael L. Starzec Blitt and Gaines PC Lauren Valenzuela, Esq. Performant Recovery, Inc. Brian Watkins Southern Oregon Credit Service Roger D. Weiss CACi

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2019

TOP RECEIVABLES PRODUCT OF THE YEAR

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50

RECEIVABLES PRODUCTS

RECEIVABLES ADVISOR

COLLECT

Interactions

TECH19

Kirby Miller, Erin Stewart & Nathan Anderson

Accelerated Data Services Gerald J. Letofsky

Castel Communications Stephen Felano

Applied Innovation Inc. Michelle Jeffers

CompuMail Inc. Stephanie Kaster

HighRadius Harris Kirkpatrick

Delvepoint Jeff Evans

NLP Logix Katie Bakewell Samantha Hartman Tom Rauch

Attunely Trip Edwards

Balto Software Rob Westervelt

DKBinnovative Keith Barthold

FICO Arjun Bajaj, Leah Huyard, Nags Odedra & Shaheen Fernandes

Palinode Ron Bonavita Joe Sage

TOP 50

Receivables Products of the Year

INNOVATIVE PRODUCT OF THE YEAR Pairity Marc Cataldo & Daniel Baker

PCI Group Anthony Faldetta

Prodigal Technologies Jason Prudlow Shantanu Gangal

Sentinel Development Solutions Wes Baldwin

Solutions By Text Gabe Manley

Telrock Rob Fite

Thrio Edwin Margulies

Provana Anant Saksena

Tech Lock Steve Akers

RevSpring Bill Needham

VoApps Neal Jagoda Todd Santa Maria

Accelerated Data Services Applied Innovation Inc Arbeit Software Attunely Balto Software Castel Communications CDS Software Codix The Collections Coach CompuMail Inc. Comtech Systems Comtronic Systems Cornerstone Support CSS Customer Communication Services - FICO DAKCS Software Systems Debt$Net Delvepoint Digital Recognition Network DRN DKBinnovative FICO - Decisions Debt Manager HighRadius Intelligent Contacts InterProse Katabat LexisNexis LiveVox MicroBilt NLP Logix NPC Pairity Palinode Payment Savvy PCI Group PlugNPay Prodigal Technologies Provana Quantrax Corporation RevSpring Sentinel Development Solutions Simplicity Collection Software Solutions By Text SpeechIQ Tech Lock Telrock Thrio VeriFacts VoApps VoiceSense

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INNOVATIVE AGENCY OF THE YEAR 2019 MOST INNOVATIVE AGENCY

Valor Intelligent Processing Gordon C. Beck III President COO

RECEIVABLES ADVISOR

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TECH19

TOP INNOVATIVE AGENCIES RECEIVING AWARDS AT CollectTECH19

22

ACCESS Receivables Tom Gillespie President Tim DePetris Asst. VP of Ops

CBC, Inc. William E. (Bill) Hopkinson President/CEO

Credit Collection Partners Megan Bryant Collection Supervisor

Afni Jeff Hobbs Executive Director

CBE Companies, Inc. Brian Sharp Director of Analytics

ERC Steve Manz SVP, Analytics

CACi Roger Weiss President

Credit Bureau Services, LLC Debbie Frank CEO

MRS BPO LLC Christopher Repholz Chief Client Officer

State Collection Service, Inc. Tim Haag President Traci Dudek COO

Omni-Channel Collections Continued from page 17 collection operations that want to move to a more holistic and frictionless collection approach. One that can help them achieve a better customer experience, drive more overall collection efficiency and effectiveness, lower operational expense, while adhering to compliance requirements.

The good news is that certain modern collection software platforms coming to the forefront of the collection industry have been designed and built new, from the ground up, with modern technology, and more intelligent designs. They provide the latest capabilities needed for today’s collection environment, including omni-channel collections.

In order to properly and more fully support an omni-channel collection approach, a collection software platform must provide: • real-time processing • embedded digital channel messaging (1 & 2 way texting, email and chat) • integrated self-serve consumer collection portal • integrated multi-channel communications • a centralized rules / strategy engine • consent / contact tracking & management • real-time tracking / reporting These features and functions must be seamlessly integrated, centrally set / controlled, and perform in a highly cohesive, automated, and instantaneous manner. Only in this way can a collection software platform enable collection operations to perform collections in a holistic and friction-less communication and engagement way, otherwise known as “omni-channel collection.”

Waterfalling Data – Improving Success Rates for Right-Party Contact Niki McKinnell | Marketing Manager at Delvepoint Waterfalling is one of the most effective ways to find specific data needed for larger-volume placements or purchases, while minimizing costs and increasing accuracy. By starting your research with basic, most cost-efficient batches and progressively increasing queries, you ensure you’re getting the data you need at the best price point.

Waterfalling can have many pitfalls if not done correctly. Inadvertently reprocessing data within your waterfall can be costly and waste time. Be sure to keep these tips in Keith Barthold mind as your and Kyle Christensen lead teams discussions about the cyber waterfall data:

TECHtalk Roundtables Scrub your data first. Remove

duplicates, incompletes and blatantly incorrect data first. There’s no use running searches on faulty data.

Be sure to do a thorough scrub before starting your waterfall.

Batch the bulk. By uploading a CSV file to your data provider

with your debtors’ names, known addresses and/or historical phone numbers, you can run a batch append. In as little as one hour* of the upload, you will receive a customized listing of additional right-party contact (RPC) information, enabling you to start making contact instantly.

Once you’ve processed the first batch, repeat the process with your no-hit records through a higher-tiered data provider until you’ve exhausted all the no-hits.

Multi-task. Some data providers allow you the option to run

multiple providers in one interface, for both batch and individual searches. For example, start by running the lowest-cost persons search, then if you need more data, run the query in the next level data source within the platform. * Standard returns are one hour. Times may vary based on provider.

AMCA Breach: The Tale of a Cyber Horror Story

Keith Barthold | CEO of DKBinnovative In March 2019 news broke of a massive healthcare data breach – over 20 million records exposed from American Medical Collection Agency (AMCA), the third-party billing collections service provider for Quest Diagnostics and LabCorp among others. This nightmare was way too close to home for collection agencies nationwide, putting the ARM industry on the map as a high value target.

• 2015 – AMCA invested over $1 Million in IT and security.

• August 2018 – System hacked.

• March 2019 – Breach first discovered.

• June 2019 – $3.8 Million in mail alone for individual notices. $400K in IT consulting to identify and stop breach source identified as their payment portal. With contracts lost and class actions lawsuits forming, 113 employees reduced to 25.

• June 6, 2019 – Bankruptcy filed after a 40 year run.

Continued on page 25

revolution.

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TECH19

“

The entire setup was phenomenal!

– Amy Qualman

Gordon Beck has fireside chat with CFPB’s John McNamara.

“

Availability to vendors was great. The cadence of the presentations and speed-dating sessions Wednesday morning was the value we hoped for.

– George Buck

Myles Chavenson (right) Richard Haass

“

The last afternoon and evening social event were the best. Everyone seemed a lot more open and conversational.

– Chris Repholz TECHtalk roundtable discussions about A/R tech.

Receivables Advisor’s Awards reception under the stars

24

“

The focus on technology, venue, willingness to engage in exploratory convos, etc...my kind of show.

– John Kelan

TECHtalk Roundtables AMCA Breach: The Tale of a Cyber Horror Story Continued from page 23

What Can We Learn?

“Won’t happen to me” and “never been a problem before” doesn’t fly. In 40 years this was AMCA’s first security incident.

One crack in the wall (in this case an insecure payment portal) causes the entire castle to crumble, even with a million-dollar wall.

Can an agency survive amidst this cyber battlefield? Yes!

Protection alone is no longer an adequate cyber defense.

Identify threats by performing disciplined risk management processes. Asset threat mapping is one approach. By identifying what is being protected (payment portal data) and what could go wrong (a threat like loss of confidentiality, integrity, or availability) we can quantify the risk and then prioritize where to focus security investments.

Breach detection is a must-have. Does a bank only rely on locked doors? No! Motion detectors and surveillance cameras notify law enforcement immediately when doors or windows are breached. AMCA didn’t know they were being hacked for 8 months, and traditional anti-virus and firewalls will not detect a breach. SIEM and a 24x7 SOC (security operations center) identify hack attempts so actions can be taken to stop a breach and avoid this nightmare.

Identify and detect are two critical framework functions that can’t be ignored in today’s cyber-secure agency.

Applying Automation and Artificial Intelligence to Credit Dispute Investigation

Things to consider:

• When you stop investing in your business eventually you stop growing or worse.

• Waiting to the last minute sometimes is more costly for several reasons.

• Focus on revenue generators.

• Consider Automation, use artificial intelligence or machine learning only if it can outperform your manual processes at a reasonable price.

• Increase ROI by automating, using AI or machine learning for non-revenue producing/repeatable task like automating much of your e-Oscar and direct credit disputes with a software like Sonnet.

Future proof your technology:

• Utilize technology and platforms that can easily add on automation, artificial intelligence or machine learning.

• Automate to organize processes that are repeatable, nonrevenue generators that require compliance.

• Automate or utilize other technology in areas of business that human error can prove costly in fines or lawsuits, etc.

• Improve needed documentation with automation or AI. Vet all vendors and technology before purchasing. Call unsolicited references. If it’s affordable and outperforms your current process, evaluate the ROI and update technology for the future of your business.

Joe Sage | VP of Business Development at Palinode All agencies are so busy, management and owners are pushed in so many directions. You may have a ton of projects on the IT board to do and others to consider.

So, common decisions or thoughts are:

• Status Quo: We are very busy and we are doBill Needham ing alright doing things our current way, I think? and attendees • Don’t want to spend money right now: I interact about digital don’t want to spend money on things if communication they are working. strategies.

• It’s not in the budget for this year.

• I don’t want to disrupt the department with another new process this year.

• Last time we purchased the newest, best thing it was not good for us. I’m hesitant to purchase new technology.

• I know we need to evaluate this so add it to the list or just hire another person.

RECEIVABLES ADVISOR .com

January/February 2020

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Business Directory Client Web Portal Applied Innovation Inc. ClientAccessWeb, PayStream, GreenLight, and Papyrus appliedinnovationinc.com 800-589-5651 mjeffers@appliedinnovationinc.com ClientAccessWeb allows your clients to self-manage and maintain compliance. Robust reporting, placements, and secure messaging, hosted in our private cloud. Streamline your business and boost productivity.

Collection Agencies IC System, Inc. 3rd Party Collections

icsystem.com 651-481-6531 ejohannes@icsystem.com IC System provides secure and compliant third-party bad debt collection services to a wide array of markets.

Over 80 years of family ownership and consistent, trusted results.

United Collection Bureau, Inc.

1st and 3rd Party Collections ucbinc.com ssharma@ucbinc.com 954-236-6027 UCB, Inc. provides national debt programs for creditors in all markets from fully-secure high performance collection centers located in the U.S. and Latin America.

Collection Software

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 | arielb@cssimpact.com 818-593-4830 CSS IMPACT! HD™ 2.0 (Enterprise), the industry’s leading ARM | Collections & Compliance Platform delivering decades of deep rooted industry acumen for the ARM, Collections & Compliance sectors. IXP (Lite) also available.

DAKCS Software

Systems Beyond ARM dakcs.com | sales@dakcs.com 800-873-2527 DAKCS Software Systems is an industry leader in simplifying the process of collections and accounts receivable management. By creating highly configurable, innovative cloud and on-premise software solutions, DAKCS offers a way to run your business faster and more efficient. DAKCS is committed to providing the tools necessary for success in the ever evolving ARM industry.

Debtmaster®

Debtmaster® 360 debtmaster.com 800-414-2814 Debtmaster®360 gives you cloud hosted, costeffective, flexible, secure, collection solutions that helps you manage compliance and provide quality service for Clients and Debtors.

Simplicity FICO Collection FICO Debt Software Manager Pro SimplicityCollect fico.com simplicitycollectionsoftware.com (858) 369-8000 sales@simplicitycollect.com FICO provides an integrated suite of solutions for case 866-791-0224 management, two-way omni-channel communicaAs an industry leader, Simplicity is the only software protions and analytics to help organizations improve vider to offer a web solution with unlimited users, clients, collection performance. accounts, and custom fields at an affordable price!

The Computer Manager, Inc. Debt$Net Collection Software debtnet5.com | sales@debtnet5.com 800-552-8397 Since 1987, Debt$Net collection software has provided collection agencies, law firms and in-house collection departments with one of the most comprehensive collection systems in the industry.

Sentinel Development Solutions, Inc. eCollections ecollections.com | sales@ecollections.com 515-564-0585 The result of 20 years 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.

CDS Software Comtech Systems CollectOne Collect! collectone.com Credit and Debt info@collectone.com Collection Support Services Collection Software 888-816-3333 collect.org | info@collect.org CollectOne is an award winning suite of debt colCornerstone 800-661-6722 lection solutions that provides a feature-rich set of Support Collect! combines ease of use with total integration automated business processes designed to minimize State Licensing of functions.

Accounts are efficiently tracked from costs and maximize results. and E&O Insurance the time you receive them until activity is concluded cornerstonesupport.com and they are closed. Collect! keeps track of critical information automatically. Total integration provides info@cornerstonesupport.com 888-445-8660 for seamless and accurate month end invoices and Cornerstone Support is the premier licensing and insurance statements with full account histories. provider to the collection industry; professionally trained to assist you with all of your state licensing needs.

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VoApps DirectDrop Voicemail voapps.com sales@voapps.com 855-639-4907 VoApp’s patented DirectDrop Voicemail service delivers a voice message directly to a consumer’s voicemail server – without calling the phone in question.

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.

Compliance

Speech Analytics

LexisNexis® Risk Solutions LexisNexis ® Accurint ® for Collections lexisnexis.com/risk/receivables-management 800-869-0751 LexisNexis Risk Solutions assist debt recovery professionals with increasing workflow efficiencies, gaining greater insight into debt portfolios, collecting more in less time and achieving greater profitability.

Cybersecurity/IT DKBinnovative

Managed IT/Cybersecurity/ Compliance dkbinnovative.com solutions@dkbinnovative.com 888-352-4832 Boost workforce productivity and stop cybersecurity and compliance threats with DKB. As your strategic partner and virtual CIO, focus on your agency while we protect and improve your technology effectiveness.

Mail Services CompuMail Inc. Print & Mail Services, Communications compumailinc.com info@compumailinc.com 360-260-1888 In addition to providing print and mail services, CompuMail’s solutions include email, online archiving, and real-time review & approve capabilities - coupled with superior service.

RECEIVABLES ADVISOR .com

January/February 2020

ADVISOR

January/February 2020 Volume 20, No. 1 Editor-in-Chief Joshua Fluegel josh@receivablesadvisor.com

speechIQ speechIQ speechiq.com sales@speechiq.com 888-683-1011 SpeechIQ is an AI-driven speech analytics and quality management platform helping companies automate and streamline quality assurance, improve agency performance, and mitigate compliance risks.

Editor T. Steel Rose, CPA, ACG editor@receivablesadvisor.com Copy Editor Myrna Nelson

Virtual Collections Applied Innovation Inc. PayStream, ClientAccessWeb, GreenLight, and Papyrus appliedinnovationinc.com 800-589-5651 mjeffers@appliedinnovationinc.com PayStream is an award winning and proven compliant virtual collector. Consumers can setup repayment plans, designed to get the highest possible payment while reducing print expenses.

InterProse

ACE - Virtual Agent Collector interprose.com/collection-advisor aaron.reiter@interprose.com 844-244-1135 Add InterProse’s consumer-friendly, patented Virtual Agent Collector to your existing software or ask about ACE for a full conversion to a true, web-based collection platform, open to third-party integrations and packed with process automations.

Skip Tracing LexisNexis® Risk Solutions LexisNexis® Accurint ® for Collections risk.lexisnexis.com 800-869-0751 LexisNexis® Risk Solutions assist debt recovery professionals with increasing workflow efficiencies, gaining greater insight into debt portfolios, collecting more in less time and achieving greater profitability.

RECEIVABLES

LISTINGS AVAILABLE 1 issue - $599 2-6 Issues - $399 each

Advisory Board/Columnists Gordon Beck Ron Brown Debra Ciskey Michael L. Starzec Harry A. Strausser III Publisher Angie Rose angie@receivablesadvisor.com Sales Destiny Rose destiny@receivablesadvisor.com Production Andrea Bergeron Paul andrea@receivablesadvisor.com Subscription Changes Joshua Fluegel josh@receivablesadvisor.com

The opinions given by contributing authors are their own and not necessarily the opinion of our staff and ownership. All trademarks used are the property of their respective owner.

Receivables 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. ©2020 All Rights Reserved Magazine Publishing Group, Inc. Printed in the U.S.A.

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RECEIVABLES

ADVISOR

Built for start-ups.

Scalable for growth.

Automate • Customize • Import • Cloud • Premise • Integrations

Demo.Collect-Cloud.com Collect.org

Demo.Collect-Cloud.com | Collect.org

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– Attendee

Marian Riso wins one of the four iPhone 11 Pros.

Say cheese...I mean, technology!

Sean Escobar (right)

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Darlene Mead was one of the four iPhone 11 Pro winners.

Everyone I talked to had nothing but good things to say.

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RECEIVABLES ADVISOR .com

September/October 2019

Gordon Beck gets the personal side of the CFPB’s John McNamara at the fireside chat.

SPEECH ANALYTICS PROVIDING IMMEDIATE OPERATIONS & QA RESULTS

WWW.CASTEL.COM