Collection Advisor November/December 2016

USING TECHNOLOGY TO EMPOWER COLLECTIONS

THE CFPB AND THE SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT WHAT IS NEW IN VIRTUAL COLLECTIONS? ARE YOU PROUD OF YOUR WEB PRESENCE? SALUTING WOMEN WHO IMPROVE THE COLLECTION PROFESSION - PART II WHAT TO AVOID WHEN IMPLEMENTING ELECTRONIC PAYMENTS PROTECTING THE CLIENT’S BRAND IN TELECOM COLLECTIONS IVR CONTINUES TO RESOLVE DEBTS WHAT THE CFPB IS “FIXIN’ TO” DO COLLECTIONS TECHNOLOGY: TRENDS FROM ACROSS THE POND WHAT IS A CREDIT SCORE? 2016 BUSINESS DIRECTORY AUTOMATIC COLLECTIONS THE INVISIBLE WEB November/December 2016 Vol. 16, No. 6

Kelly Knepper-Stephens

COLLECTORS WEIGH IN ON PROPOSED CFPB RULES

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

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4 Sam Eidson 6

Debra J. Ciskey

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Fred N. Blitt

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Ron Brown

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Harry A. Strausser III

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Sam Edens

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T. Steel Rose, Editor

THIS ISSUE MADE POSSIBLE BY: CDS Software...............................Inside Front Cover Call Evo.............................................Inside Back Cover Applied Innovation................................Back Cover IDI, Inc................................................................... Page 3 MicroBilt............................................................. Page 5 VeriFacts.............................................................. Page 7 CSS IMPACT........................................................ Page 9 Cornerstone Support.................................. Page 11 DAKCS................................................................. Page 13 CCC of NY...........................................................Page 23 Advanced Payment Systems................... Page 25 Collect!................................................................Page 25 VoApps...............................................................Page 25 Quantrax............................................................ Page 26 PDJ Services..................................................... Page 27

TELECOM COLLECTIONS

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t’s widely agreed the CFPB is the elephant in the room for every debt collection professional. Knowing the direction the elephant is going to tramp next can help collection professionals remain complaint and avoid being trampled. Fortunately the CFPB has recently released a document that reveals what it is considering to do next. Collection Advisor had the opportunity to talk with one of the few collection professionals invited to provide recommendations for the proposed action. Collection Advisor talked with Kelly Knepper-Stephens about her day with the mighty regulator.

Compliance Advisor Debra J. Ciskey describes the Outline of Proposals Under Consideration and Alternatives Considered and how it provides a glimpse into what the CFPB will possibly do next. Skip Tracing Advisor Ron Brown reveals a lesser known place on the web: the invisible web. He details ways skip tracers and collection professionals can access the invisible web to find skips. Legal Collection Advisor Fred N. Blitt discusses the Small Business Regulatory Enforcement Fairness Act and how it is creating a place for the CFPB to hear out collection professionals concerning proposed rules. Technology Advisor Sam Edens describes how automation can boost your telecom collections. Benchmark Advisor Harry A. Strausser III sits everyone down and talks about a corner of most collection agencies that needs a lot of work: the website. Strausser provides some helpful tips on how to freshen up your website with the help of an industry veteran. Agency Advisor Sam Eidson provides an overview of telecom collections and illustrates the process.

Next issue Collection Advisor will ring in the New Year with a look at legal collections. Until next time, we look forward to hearing from you.

T. Steel Rose CPA, ACS Editor

editor@collectionadvisor.com

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November/December 2016

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2016 Business Directory

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ACCESS ONLINE

USING TECHNOLOGY TO EMPOWER COLLEC TIONS November/December 2016

ADVISORS 4

www.CollectionAdvisor.com

FEATURES

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What is a Credit Score?

AGENCY ADVISOR

Protecting the Client’s Brand in Telecom Collections Sam Eidson

What the CFPB is “Fixin’ to” Do Debra J. Ciskey

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The CFPB and the Small Business Regulatory Enforcement Fairness Act Fred N. Blitt

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SKIP TRACING ADVISOR

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The Invisible Web Ron Brown

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Welcome

Collection Industry Top Product Nominees

Collections Technology: Trends From Across The Pond STEVEN PRESTON

Collectors Weigh In On Proposed CFPB Rules

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BENCHMARK ADVISOR

T. STEEL ROSE

Are You Proud of Your Web Presence?

Harry A. Strausser III

DEPARTMENTS

Product Spotlight Applying Innovations to Address the Needs of Collection Practices

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Automatic Collections Sam Edens

JOSHUA FLUEGEL

MOST INFLUENTIAL WOMEN IN COLLECTIONS

LEGAL COLLECTION ADVISOR

TECHNOLOGY ADVISOR

Saluting Women Who Improve the Collection Profession - Part II

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COMPLIANCE ADVISOR

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JERRY LOVE

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Volume 16, No. 6

JOSHUA FLUEGEL

Knowing Requirements for High-End Collection Software Comparison Chart

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JOSHUA FLUEGEL

22 23

IVR Continues to Resolve Debts

JOSHUA FLUEGEL

What is New In Virtual Collections?

JOSHUA FLUEGEL

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What to Avoid When

Implementing Electronic Payments

JOSHUA FLUEGEL

November/December 2016

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Protecting the Client’s Brand in Telecom Collections

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Have you seen the commercials where a cell phone provider offers to buy out your contract, even going as far as cutting your bill in half with a sword? They make it sound like all you have to do is sign up with them and they’ll take care of the rest. In some cases the consumer finds out months later the new provider did not do everything they promised. In fact, if the consumer doesn’t comply within a certain amount of time they won’t even get the buyout money. Eventually the consumer receives a dunning letter and even collection calls for the unpaid balance or the contract buy out amount. That’s Sam Eidson where we come in and try to assist the consumer in resolving their unpaid balance.

Often we have to overcome objections before we can even service approach and focus on the fundamentals. Showing emattempt to collect the debt. Whether the charges are for data, pathy, thanking the consumer and recapping the call are all service, equipment or cancellation, the consumer was under good ways to provide the customer service approach. the impression all is well and could be receiving collection calls From a strategy standpoint, you must be cautious with for the very first time in their life. How the collector handles how you attempt to reach the consumer. The service number the call is crucial to what happens next. The call can result a could have been ported over to the new carrier by the consumfew different ways including payment, dispute, fraud or even er or reassigned to a third party so manual dialing is crucial in worse, a complaint. It’s impororder to remain complaint under tant to make sure your agents are the TCPA. trained on how to properly handle If it’s a commercial account I “If they claim they were a victim the call if the consumer objects. If would start with accounts payable. of fraud the service provider should the consumer claims their current Your approach must be profesprovider promised to buyout their sional and assertive but rememhave a process to follow. “ contract I suggest asking the conber it’s not their debt. If you are sumer if they received a gift card to unable to get anywhere with accover the buyout amount. If they didn’t receive a gift card they counts payable check the agreement to see if there is a permay not have complied with the fine print of the agreement. sonal guarantor and attempt to reach them. If all else fails I If the consumer adamantly disputes then the collector should attempt to reach the owner of the company. The owner may back off and offer to provide invoice copies. Once the con- not be reachable at the office so you may have to skip trace in sumer understands what the charges are for it makes our job as order to find their home or cell phone number. I use Accurint collectors easier. If they claim they were a victim of fraud the and search the businesses name then click on the “People at service provider should have a process to follow.

Work” feature. Once you make contact with the owner reWhen collecting for a service provider it is imperative to member to take a soft approach. In most cases the owner of protect their brand by treating the party on the other end of the company isn’t aware the debt is unpaid and more than the phone with dignity and respect. The last thing you want likely isn’t used to receiving collection calls. The purpose of to do is leave a bad taste in their mouth due to an unpleas- calling the owner is to notify them of the amount owed and ant experience. Not only because they may never come back get them to instruct their accounts payable department to pay to the provider but also because anyone they speak to about the debt. Owners are used to giving orders not taking them so their experience whether it be friend or family may think twice handle with care. about using your client in the future. I’ve found it to be more difficult to train pre-CFPB collectors because of the old saying, Sam Eidson is the Director of Compliance for Delta Outsource “you can’t teach an old dog new tricks.” Ideally I look for col- Group, Inc. He also serves on the Board of Directors for the Mislectors with less than five years experience. We take a customer souri Collectors Association.

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November/December 2016

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COLLECTION & RECOVERY Keep your skip tracing & debt recovery efficient and effective.

800-884-4747

microbilt.com

What the CFPB is “Fixin’ to” Do

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My in-laws live in Texas, so I have spent a considerable amount of time there over the last 40 years or so. A colloquialism used there, and no doubt in other places as well, is “fixin’ to”, as in, “I’m fixin’ to get to the market.” It means preparing to do something, or considering to do something. As I read through the CFPB’s July 28 document titled “Outline of Proposals Under Consideration and Alternatives Considered,” I got that “fixin’ to” kind of feeling, as in this document is what the CFPB is “fixin’ to” consider doing related to rule making for the debt collection industry. I have a number of opinions about its content, but in this article I want to point out areas of concern we need to think about in terms of “if we had to change how we do this, how could we do it effectively and efficiently?” This document should spur thinking, brain-storming, creativity and discussion in the executive offices, IT departments, compliance departments, and operational units, separately and together. This should be done while we have the time to do so, should these proposals, or even amended versions of them, come to pass. (The entire proposal can be found at http://files.consumerfinance.gov/f/ documents/20160727_cfpb_Outline_of_proposals.pdf) The most challenging proposals, in my opinion, are those that require or encourage a response from a consumer. For example, the example initial notice provided in Appendix F of the document, provides a tear off form for the use of the consumer to dispute the debt or to enclose with payment. We all use stubs

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Compliance Advisor Debra J. Ciskey

on our first notices already, so no issue there. However, we can all attest that we see very few of these coming back. Consumers are much more likely to call than return the stub with payment.

Consumers are also more likely to call with a dispute than they are to send something back in the mail, even if the letter is pre-written for them with check boxes related to the reason for their dispute.

Even more problematic is the proposal to require an obsolescence disclosure to consumers on old debt, obsolete for credit reporting, and the subsequent proposed requirement for the consumer to provide written acknowledgment of receipt of the disclosure before the debt collector may accept payment of the debt. Just how is that going to work? Thinking caps on!

The other proposal related to credit reporting by debt

DISPUTE CATEGORY

DESCRIPTION

PROPOSED VALIDATION

Generic Dispute

Disputes in which the consumer provides no details.

Consumer’s full name, address, and account number with original creditor, date of default and last payment date, name and address of creditor at time of default, balance at default and post-default interest and fees, and description of the amount owed.

Dispute as to the amount of the debt

Consumer challenges the amount sought to collect.

Amount of the principal, interest or fees disputed, including terms and conditions related to post-default interest and fees, the date and amount of each payment (or other credit) after default, any other specific information required to respond to the specific dispute.

Collecting from wrong consumer

Consumer asserts he/she did not incur the debt or the collector is contacting the wrong person.

Information the consumer provided to the creditor such as consumer’s date of birth and the consumer’s addresses throughout the life of the account.

Identifying numbers uniquely identifying the consumer, e.g. taxpayer ID number, SSN, EID, ITIN. Copy of credit application, new patient form, etc.

Wrong collector

Disputes in which consumer asserts the debt collector is not the owner of the debt or not entitled to collect the debt.

Bill of sale or assignment of the debt.

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“The ‘wrong collector’ category goes far beyond the intention of the Fair Debt Collection Practices Act.” collectors relates to what the CFPB calls “passive collection” or “debt parking.” The proposal is based on the Bureau’s conclusion that debt collectors use a cost v. benefit calculation (cost of actively attempting to reach consumers exceeds the expected return from engaging in collections) to determine which accounts to send an initial notice and which will receive a notice only after contact; which is primarily a contact to the debt collector by the consumer related to a collection account on his credit report. The proposal would prohibit furnishing a debt by a debt collector unless the debt collector has communicated directly about the debt to the consumer, e.g. sending a validation notice. The proposal does not address returned mail, misdirected mail or other instances in which the consumer may not have received the initial notice.

The proposal, in appendix D, defines categories of disputes and describes what could constitute validation for each type. This summary, SEE TABLE AT LEFT, may spur discussion.

While it could be helpful to have comprehensive definitions related to validation, sending information described in the “wrong person” category to the actual wrong person invites identity theft and further problems for the actual consumer. Often, a dispute

we might label as “I did not incur this debt” is very different from “you are collecting from the wrong person.” Processes and procedures for responding to disputes in these categories will be required. The “wrong collector” category goes far beyond the intention of the Fair Debt Collection Practices Act. Any debt collector with the ability to create a legitimate validation notice for a debt must be assumed to be the right debt collector.

Scammers do not provide consumers with a validation notice.

This is not a comprehensive review of the proposal. The document should be studied and discussed, even though it is merely a peek into what the CFPB is “fixin’ to” do. Think about the feedback you would be willing to provide the CFPB when the actual proposed rules are published—there will be a comment period. Finally, think about and discuss ways in which you can be “fixin’ to” comply, when and if we get to that stage with these initial proposals.

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.

The CFPB and the Small Business Regulatory Enforcement Fairness Act

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On July 28, 2016, the CFPB released its outline of proposals it is considering for debt collection regulation prior to convening a small business review panel. The Small Business Regulatory Enforcement Fairness Act (SBREFA) requires that CFPB convene such a panel when proposed rules may have a significant impact on a substantial number of small businesses.

Legal Collection Advisor

The Numbers In its outline of proposed rules, the CFPB

noted the importance of debt collection to our overall economy.

However, the CFPB indicated the largest amount of complaints on its portal comes from debt collection activities. While I have been in favor of a mechanism giving consumers an opportunity to express complaints, since the onset, I have always been concerned about the integrity of the data being submitted and the use of the reporting. As of now, the CFPB’s portal only collects complaints.

It does not verify the correctness of the data. It seems like every week new data is used to justify new regulations. I would like to see this data verified and reviewed prior to using it as a basis of new industry rules.

The Proposals

I have written extensively about the CFPB and consent decrees over the past few years. For collection law firms with robust compliance programs, the majority of proposals are not much different than what we have already been doing.

Some of the key points are as follows: Substantiate the Debt Before Contacting Consumers - Collectors would have to confirm they have sufficient information to start collections, such as the full name, last known address, last known telephone number, account number, date of default, amount owed at default, and the date and amount of any payment or credit applied after default.

Limit on Communication - The CFPB has stated it received a vast amount of consumer complaints regarding being repeatedly contacted by debt collectors. The CFPB wants to limit the number of calls and frequency of calls to consumers.

Consumer Understanding and Dispute Process - The CFPB proposes a new series of disclosures to assist consumers in understanding and recognizing the debt. These disclosures are also meant to inform consumers about their rights, including the right to dispute the claim. The proposals contain a new form of an initial demand letter which includes a “tear-off” portion consumers can send back to the debt collector with check-off boxes to identify a dispute or indicate willingness to pay the debt. The CFPB also mentioned having a portion of the initial demand indicate the name and address of the CFPB and the manner to file

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a complaint. My concern would be that this type of notification would only increase the number of complaints. This would make a complaint verification process even more important!

Stop Collecting or Suing on Debt Without Proper Documentation - If a consumer disputes the validity of the debt in any way, collectors would have to stop collections until the necessary documentation is checked. Collecting on debt that lacks sufficient evidence would be prohibited.

Other Topics

Somewhat surprisingly, the proposed rules did not seem to want to tackle the 40-year-old provisions of the FDCPA relating to communication with consumers. In my experience, many consumers would prefer to deal with their accounts via email or text. Frankly, I feel this would be a huge consumer benefit that must be part of the discussion. The vast majority of consumers want to pay their bills; however, they do not want to have to spend time on the phone dealing with a cumbersome process. Think about it, each time a consumer calls our office, we need to go through the same verification and disclosure process that the regulators and our clients require.

In addition, there was discussion about the application of the FDCPA to first-party debt collectors. The CFPB said this topic would be address in the near future.

Finally, it will be interesting to follow the progress of the rule making through the SBREFA panel and into 2017. It does not seem likely that rules will be issued any time soon. All of the major collection industry groups have chimed in on the issues. Debt collection truly has a major impact on our nation’s economy. Many small companies will be impacted by these rules. I’m hoping the CFPB really weighs true consumer benefit to major small business hardship when issuing rules.

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. November/December 2016

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WHAT IS A CREDIT SCORE?

BY JERRY LOVE, CPA/PFS, CFP, CVA, ABV, CITP, CFF, CFFA

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his is a question on many people’s minds. A few years ago consumers were trained to monitor their credit report. However, now consumers are seeJerry Love ing commercials asking, “Do you know your credit score?”

So what is a credit score? Who creates this score? And what does it mean to the consumer? There are 19 major versions of credit scoring models in use today. However, there are two major credit scoring systems. The most commonly known is the FICO Score and the other is VantageScore.

MyFICO.com gives us the background and foundation for the FICO Score: “90% of top lenders use FICO Scores to help them make billions of credit-related decisions every year. FICO Scores are calculated based solely on information in consumer credit reports maintained at the credit reporting agencies.

“By comparing this information to the patterns in hundreds of thousands of past credit reports, FICO Scores estimate your level of future credit risk.”

Bankrate.com elaborates more on the FICO Score: “Technically, it’s a predictive analytics company founded in 1956. But, generally, when people hear “FICO,” they’re thinking of the scores it gives -- threedigit numbers introduced in 1989 that essentially determine “the likelihood that you will pay all of your (debt) obligations on time for the foreseeable future,” says Barry Paperno, former consumer affairs manager for FICO who now runs the blog SpeakingOfCredit.com.

“The first FICO scores, and their descendants, predicted the likelihood a consumer will become 90 days behind on payments over the next 24 months on different debt types. Over the years, the score

has been poked, prodded and tweaked from its original formula to account for changes in consumer behavior and the lending landscape, says Frederic Huynh, senior principal scientist at FICO.” Credit.com gives us an excellent overview of VantageScore: “VantageScore first exploded on the credit score scene in 2006 as a joint venture of the big three credit bureaus – Experian, Equifax and TransUnion.

“Like other credit scores, VantageScore consists of calculations relying entirely on credit bureau information – not income, bank accounts or other assets – to predict how likely you are to pay your credit obligations on time each month. With an emphasis on paying on

July/August 2015 www.CollectionAdvisor.com .com November/December 2016

time, keeping balances low, and avoiding new credit obligations, the simplicity and common-sensibility of credit scores are often marred by the all-too-frequent credit reporting errors that can lead to credit scoring errors, and that can require active management of your credit – much like managing your health.”

CreditKarma.com gives us some context on the evolution of the credit scoring system: “Prior to the creation of standardized credit scores, lenders and loan officers would often develop their own “score card” to assess the risk of lending to a particular borrower. This score card could vary drastically from one lender to the next. The Continued on page 11

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The Invisible Web

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I was recently asked, “When are you going to run out of tracing material to write about?” As I pondered this question a smile came upon my face, or maybe it was a smirk, and I replied, “Probably never, because the science and art of skip tracing and cyber tracking are constantly changing and advancing with the progress of communication technology. Our ability to trace has always paralleled our ability to communicate.”

In this short missive I would then like to bring you a new tool and technique that has evolved in our industry. It is currently being used by many professional men and women who have chosen the exciting and rewarding vocation of hunting the most dangerous prey on the face of the earth, man.

Ron Brown There has been a lot of talk recently among professional tracers and cyber trackers regarding getting data from the “invisible web.” This is actually not a new tool but there is a newness start by building yourself a list of gateways classified by subjects in its understanding and actual use. which you will use as the foundation for your tunnel into the The invisible web is a huge repository of databases most invisible web. search engines and online directories do not have the capability I would suggest you start by locating sites which could be to access. While the visible web is one you can access via search classified as mega portals. Mega portals contain links to incredengines and directories, the information in databases is gener- ible numbers of links covering every subject known to modern ally inaccessible to the software spiders and crawlers that create man such as: search engine indexes. It is generally thought the invisible web • The University of California, Riverside maintains Info- has a volume of content thousands of times larger than the Mine, an incredible resource that at last count includvisible web. ed over 100,000 links and access Most professional tracers use to hundreds, if not thousands, of “These search engines are unable to see Google, Yahoo and Bing search endatabases. To utilize this tool gines which usually do not extract go to infomine.ucr.edu/ hidden content without specialized search simply all the hidden content in a typical research-services/databases or go parameters and/or search expertise.” search. These search engines are unto the website (infomine.ucr.edu), able to see hidden content without hover over Research Services then specialized search parameters and/ click Databases. or search expertise. The true professional tracer understands that • The Virtual Library is another excellent source of mega data a very special little spider scurries about on the web. These spiwhich I find to be very simple and easy to use, with annoders index the addresses of particular data that they discover. tated subject links. To access this go to vlib.org and choose Spiders can record the address, but can’t relate the information your subject. the page contains due primarily to factors such as technical barriers and owner discretionary choices. Many sites which require The invisible web can open many doors for the professional a password to enter are not capable of being discovered by search tracer and increase their chance for success as it offers an incredengine spiders. ible amount of data on any and all subjects. Resources on anyWhile the skip guessers may continue to use only the data thing you can possibly think of can be found. The links listed they find with Google or Yahoo, search engines that only search in this article barely begin to touch the vast resources you will a small portion of the web, the true professional will embrace find available. I would anticipate as time goes on, this resource this new technology and develop their ability to delve much will only grow larger and contain more useful data for the users. deeper into the vast repository of data on the invisible web.

In the next issue we will provide and explore more sites By now you should be asking yourself, “How do I get access available on the invisible web. Until then…good luck and good to this invisible web and how do I make it work for me? You hunting my friends! begin with a Starting Point consisting of an open mind and a Ron Brown is a member of the National Association of Fraud Investidesire to be the best; a desire to locate people and things which gators and the author of “MANHUNT: The Book.” Contact him at others have given up on after expending their best efforts. You rbrown2150@aol.com.

Skip Tracing Advisor

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“Credit reporting errors that can lead to credit scoring errors, and that can require active management of your credit – much like managing your health. “ What is a Credit Score?

Continued from page 9 major issue with this original method was that it was based on a loan officer’s ability to judge risk, rather than a common set of rules and specific calculations.

“So, in the 1980s, the Fair Isaac Corporation set up the first general purpose credit scoring system based on credit bureau information in order to help remove the inherent inconsistencies that arose from having each lender perform their own credit diagnostics.”

Bankrate.com explains this for us: “Your credit score is a three-digit number generated by a mathematical algorithm using information in your credit report. It’s designed to predict risk, specifically, the likelihood that you will become seriously delinquent on your credit obligations in the 24 months after scoring.

The Consumer Financial Protection Bureau indicates the most common

factors used for the credit score are 1) your most recent credit activity, 2) how long you have had your accounts open and 3) whether you had any debts referred for collection, foreclosure or bankruptcy. However, perhaps even more importantly the Equal Credit Opportunity Act (ECOA) prohibits the use of certain items for use in the calculation of your score. These are: 1) Race or color, 2) Religion, 3) Sex (gender), 4) National origin, 5) Marital Status and 6) whether you have formally disputed information contained on your credit report.

Overall the factors align in five broad categories: 1) 30% is amount you owe, 2) 35% is payment history, 3) 15% is length of credit history, 4) 10% is new credit and 5) 10% is credit mix. Some of the items used to calculate your credit score are: • Payment History • How long your accounts have been open and available for you?

Generally, more is better.

• How long it has been since you used certain accounts?

• How long specific credit accounts have been established?

• What percentage of your available credit are you currently using?

• How many accounts are listed on your credit report?

• The age of your oldest account, the age of your newest account and an average age of all your accounts.

• The mix of credit cards, retail accounts, installment loans, finance company accounts and mortgage loans.

This article is continued on www.CollectionAdvisor.com.

Jerry Love is the sole owner of Jerry Love CPA, LLC in Abilene, Texas. In 2006-07, Love was the Chairman of the Texas Society of CPAs.

INDUSTRY MOVEMENT John Hambrick John Hambrick, referred to by many as the mayor of the collection profession, returned to MicroBilt in September after 16 years. Hambrick originally worked for MicroBilt from 1984 to 1999. After leaving MicroBilt in 1999, Hambrick helped establish Banko, which was later sold to LexisNexis in 2003. Hambrick will now serve as Senior VP of Business Development for Kennesaw, Georgia-based MicroBilt. MicroBilt provides decision critical information to assist businesses in reducing risk with a wide selection of data products for fraud prevention, consumer financing, debt collection and background screening.

Contact Josh@CollectionAdvisor.com to announce industry hires.

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November/December 2016

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Are You Proud of Your Web Presence?

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As we immerse ourselves in the technological age, we sometimes forget how far we have come in recent decades relative to technological advancements. We have experienced more change in the last 30 years than in the entire lifetimes of our predecessors. It wasn’t long ago we were filing ledger cards, using rotary phones, taking messages for colleagues on pink slips of paper, running to phone booths to make important sales calls while on the road and scrolling through the Yellow Pages to find a business resource.

Today, information is only seconds away as we access the World Wide Web to access data on virtually every known topic instantly. We become impatient when having to wait for the answers we require. Every time a question arises we simply Google the data.

Traditionally, most collection firms have spent financial resources creating collateral material to place in the hands of prospective clients. We continue to produce these materials for trade shows and face to face meetings, but by far most of the business community obtains the information they need about us via our website. Web presence is not only the norm but the expectation today. While most firms spend much time fine-tuning the technologies in the office setting, often websites are out of sight, out of mind and lack the updated content and contemporary feel necessary to promote your firm. When was the last time you seriously looked at your website? I must admit, our firm has failed in this area. Visit my website and you can see a nice picture of me and my business partner from about 14 years ago!

I recently had a great conversation with Duane Watson, CEO of Greenleaf Creative, LLC. Duane heads an experienced team that assists companies with their various levels of digital marketing. According to Duane, here are some important best practices for consideration when assessing your web presence: • Mobile Ready: Be sure your website is Mobile Device Ready! Everyone accesses websites via their mobile devices today.

• Text: Be sure text is large and legible.

• Buttons: Incorporate big, easy to click buttons.

• Images: Utilize images that resize for optimal viewing and fast loading.

• Accessibility: Be sure your information is easy to find, even on the smallest mobile device.

• Interactivity: Enhance site interactivity through custom forms, client relationship management tools, online transactions, secure payment functionality and file transfer/sharing ability.

• SEO: Become familiar with SEO (Search Engine Optimization). The craft of coordinating all of the elements on a web page in a way that best communicates the topic and purpose of a page to the search engines in a way that makes it easier for them to display your page in search results.

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Benchmark Advisor Harry A. Strausser III

• Key Words: Everyone in the industry is trying to be at the front of the online searches. Creativity and strategy in this area are vital to keeping your company at the top of searches. Websites require careful and purposeful key word placement for top positioning within the search engines. Ranking for the right key words can make or break your website.

Most of us are good at managing our operations but lack the knowledge and skill to manage our online and social media presence. Michael Lively of Greenleaf Creative recently shared some industry recommendations that may prove valuable to anyone striving for online marketing success: 1. Create Passionate Copy: Passionate about solving a potential client’s problem.

2. Regular Social Media Updates: Keep your site current. A good rule of thumb is no more than two months old.

3. Content: Publish new content on a regular basis.

4. Guest Blogging: Expand your audience by publishing content on someone else’s blog. Others will notice you and Google will start to think you are important!

5. Create a Satisfying User Experience: Reward users with a good experience and ease of navigating your site.

Most of us may not be online marketing gurus but we know what sites we like and those we find cumbersome. Start recognizing these positive and negative traits and apply them to your own web presence. Reach out to industry experts, as we do with many dynamics of our companies, and obtain the best advice possible. It is critical to keep your organization current, recognized and successful!

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.

November/December 2016

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13

Automatic Collections

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Nearly ten years ago, I read a book titled “The Automatic Millionaire” by David Bach. It is a lesson on accumulating wealth and achieving financial independence. The subject is not important here. What is important is how it is accomplished because we attempt to apply the same concepts in accounts receivable management and I believe it is particularly imperative when working telecom paper. That theory is “make it automatic.” In the book, the easiest way to achieve financial independence is to make the process automatic through the use of automated payroll deductions, account rebalancing and other such processes.

Then, we do not have to do anything or really even think about doing anything. It just happens.

When it comes to timing, of course you do not have 20 to 30 years to collect on any one telecom account but what if we could apply the automatic practice to the collection efforts?

What would that look like and how could your technology be the workhorse?

Voice and data providers are always competing to reduce costs and come up with efficient ways to manage customer payments. The service has become commoditized and thus makes it simple for customers to switch providers with little care for any current or past due balances. According to multiple sources, including a white paper published by HCL Technologies, the telecom industry loses in excess of $10 billion annually due to bad debt. That number is much too large to ignore the “make it automatic” concept.

Before automating anything in your software, design a flow that makes sense. It may be helpful to refer to this as a schedule of action. Allow me to explain the automatic setup in your software using the following flow as an example:

Investigation

Setup your system to begin investigative efforts immediately.

The new business process should be constructed with logic to identify consumers with missing information. You may discover some accounts are missing too much information for collection attempts. For the rest, make sure the workflow in your software identifies consumers for immediate skip tracing and scoring. Labeling these consumers with a tag or status will make it easy for an automated interface to pick them up for transfer to your skip tracing or scoring service provider.

Dialing and Sending Notices

Like the investigative efforts, the workflow in your software should be able to automatically label consumers for required notices and be scheduled to either print the notices or transfer the requests to your letter vendor. Additionally, whether using a dialer or manually dialing, ensure the dialing pools built by the software are based on your secret sauce (balance, geographic location, credit score and so on).

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ROUTING SLIP Initials

Date

Technology Advisor Sam Edens

Reminders

As a consumer, telecom bills are one of the easiest payments to overlook. This remains true for telecom accounts in collections as well. Setting up time-based events as reminders for consumers is imperative. Make sure your software is configured to automatically issue urgent letters, send emails or dial the consumer over the course of attempting to collect on the account.

Disconnect

When calls, notices and reminders are ignored, it is helpful to have a time-based event in your software to commence the disconnect process. This could be a simple pop-up when the account is accessed or an automated message to the service provider to cut the service. If the consumer is already in collections and still has full or partial service, nothing should get their attention like disconnecting the service entirely.

Blacklisting

When all other automated attempts fail, blacklisting is the most aggressive action. Here again, a time-based event should be configured in your software to commence this process. This will eventually require some manual intervention but knowing when to start the process and perhaps some initial actions can be automated. Blacklisting can follow a few different paths. It may involve hot-lining by redirecting all calls from consumers to a special department or in more extreme examples, include barring the consumer for service not only from one provider, but from all providers of similar telecom services.

Applying the “make it automatic” concept to telecom collection efforts may not make you a millionaire but it could certainly ease the effort of working your share of the $10 billion of bad debt every year in the telecom industry.

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. November/December 2016

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MOST INFLUENTIAL WOMEN IN COLLECTIONS

Saluting Women Who Improve the Collection Profession - Part II

The pervious issue of Collection Advisor saw the presentation of the 25 Most Influential Women in Collections. Anyone who as ever attempted to assemble a list of superlatives knows it is a daunting task that can never truly be complete. In light of such a truth, Collection Advisor would like to present an addition to the Most Influential Women in Collections.

The following women, like those mentioned in the pervious issue, work toward the perfection of debt collection, improvement of the industry and the promotion of compliance education. Evidence of this ongoing influence can be found in collection agencies, law firms, presentations at trade shows and their proactive efforts in trade organizations. The following Most Influential Women in Collections answer the question, “What opportunities has collections offered you?”

JANICE HINES

President and CEO | ECMC

“My role allows me to help students become financially literate, repay their student loans, and lead healthy financial lives that contribute to our country’s economy.

JESSICA HARTMANN

Sr. Director of Association Services | ACA International Executive Director | IACC

“I have had the tremendously rewarding opportunity to strengthen the industry by bringing collection professionals together for

education, collaboration, innovation and sharing of best practices.”

WANDA BORGES Owner/Member | Borges & Associates, LLC

“During my 37 years specializing in creditors’ rights, I have had the opportunity to assist corporate creditors in the collection of their outstanding receivables and protect their rights in bankruptcy

matters through resolution or litigation.”

The Most Influential Women in Collections and many different kinds of lists that have come before it are the result of proactive communication. The collection community is one that performs best when interconnected through work, industry events and publications. If you know a collection professional, collection agency or law firm you think exemplifies the traits of a true asset to the collection profession then contact us at josh@CollectionAdvisor.com. Submitting the name and contact information of a person or organization will enter them into consideration for various superlative lists and articles to be featured in future issues of Collection Advisor.

15

Product Spotlight

Applying Innovations to Address the Needs of Collection Practices

BY T. STEEL ROSE

A

pplied Innovation, Inc. was founded in 2001 by a couple of collection agency owners who were looking to address the technological needs of their agencies. The original product was a client portal where a collection agency client could check on current accounts, run reports and assign new accounts. Since then the company has expanded offering multiple products to address the many needs of a collection practice.

ClientAccessWeb

ClientAccessWeb is a client access portal for account placements. This enables agencies to receive placements with integrated account templates and integrate with the major collection software products. It provides clients interactive account inquiry screens along with webenabled, on-demand reporting tools. It also provides secure client messaging which Christie Porter with SCB Associates said, “generates positive feedback and trust with our clients.”

Agencies are also able to receive direct payment and cancellation reports.

Steve Simon, vice president of compliance and quality assurance at Caine & Weiner, expressed he has been pleased with the secure and dynamic online interface, the ease of product’s customization and its data mining capabilities.

PayStream

PayStream is a companion product designed to help consumers pay their bills and agencies to accept payments online.

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It functions as a “virtual collector” walking consumers through the web-initiated collection process. Agencies can tailor payment negotiations to the consumer’s financial abilities in a secure environment. “Remit’s clients use it regularly,” noted Harry Strausser III, president of Remit Corporation.

An agency can control compliance by customizing the site language, such as the mini-Miranda, site usage disclaimer and funding page text. Brad Edwin, owner of Credit Bureau of Albert Lea, stated PayStream is, “on a platform that allows full control over site compliance in a safe environment to maintain fully PCI complaint integrations with payment processors.” Payment options offered to consumers via the site can also be customized according to an agency’s specifications.

PayStream is integrated with many payment processors. It is hosted on the servers at Applied Innovation and can be linked to the agencies website.

Papyrus

It is believed professionals spend 50% of their time looking for files, but only 5% to 15% actually reading them. Applied Innovation offers Papyrus, a document management system meant to help a collection professional stay on top of the numerous documents at his or her disposal and reduce the amount of time sifting through them. Papyrus aids in printing copies, filing documents and retrieving and delivering reports. It also enables users to search for files based on

content and automatically file reports based on text.

Papyrus provides access to required documents by linking document types to a certain “file folder” or file type, to help automate workflow.

It features secure storage and access through a web browser so collection professionals can access files from anywhere but the office maintains a record of who is looking at each consumer file, end of month reports or any other sensitive records. Documents can only be accessed by those granted permission to access. IP address restrictions can control from where employees or clients are able to access the documents.

To reduce time spent processing month-end reports agencies can automate the processing of statements by merging them with a custom PDF layout or convert text reports such as commission reports, paid and unworkable reports, and productivity reports into searchable PDF files.

The need to print any records could be eliminated with pure electronic document storage. Any file originating electronically can be printed to a file and stored in Papyrus. When a document must be delivered interoffice or to clients, it can be done through the secure Papyrus interface.

For innovations applied to collections, Applied Innovations solves needs on the collection floor and then makes these solutions available to collectors everywhere.

November/December 2016

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COLLECTIONS TECHNOLOGY: TRENDS FROM ACROSS THE POND

BY STEVEN PRESTON

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he credit landscape in Europe is best understood by examining the significant UK market. Research from the consulting firm, L.E.K, shows that unSteven Preston secured consumer debt balances represent approximately 100% more than the other Western European countries combined, and at the time of the economic downturn, the UK was actually the most indebted country in the world (The Independent). The last four years have seen lending continue to increase with estimates showing the total UK unsecured debt to be around £1.47 trillion according to the Centre for Social Justice.

This is against a credit active population of around 44 million.

The fallout from the economic downturn in 2007 has brought about some of the most significant regulatory change in financial history. Most notable are the new regulator’s demands for designating named individuals with the responsibility for the conduct and best treatment of the customer throughout the life of the agreement. Essentially, the Financial Conduct Authority (FCA) is ensuring the credit issuer continues their responsibility to an account even if it is with an outsourcer or third party agency.

Naturally some of the larger first party issuers have stopped issuing contingency debt and are focusing entirely on the sales channel, therefore passing on the responsibility to the new account holder (the purchaser). If first party entities haven’t done this, they’ve certainly reduced the number of third party agencies on their panels. The majority of agencies now work accounts on behalf of purchasers, rather than issuers, and much of the insight and ancillary data that used to be obtained through years of working with and building relationships with issuers has gone, reducing the .com

validity of any scores or analytics and increasing operational costs.

The regulation means that anyone that works the accounts has to prove that the account was treated fairly and the best possible outcome was determined from the customer’s point of view. Affordability assessments are required for repayment plans and these have to be auditable for future reference. All of this ultimately has an effect on the bottom line. In fact, the average call time has increased from 10 minutes to 25 minutes and the account to collector ratios have decreased from around 700:1 to sub 500:1 — significantly increasing the cost of service. Many of the purchasers are now working close to single digit I.R.R due to the increased costs of servicing.

This approach is now also spreading into other parts of Europe, with similar regulation recently deployed in Ireland and an intention from the European central bank to follow FCA principles as “best practice.”

The Challenges

In pursuit of continued growth, the established UK purchasers are looking beyond the depleted UK market and are looking at Europe with mixed success. Some organizations are concentrating their efforts in Southern and Eastern European countries, but it’s not an easy landscape. One company pulled out of Spain after just 12 months of activity.

Operating in a completely new environment, with no historical performance data or a thorough understanding of the social and cultural attitudes to debt, has led purchasers to invest heavily in analytics, online scoring tools and financial modeling as well as other technological solutions.

Technology is the “Must Have” Commodity Investment in technology is definitely the key to future economic viability. Some of the larger first parties are already using automated voice messaging as a precursor to the call to provide a small

November/December 2016

efficiency gain back into their call centers.

Almost every entity now has an IVR and an online payment portal as a minimum.

Most noticeable however, is the migration towards digital communication channels, with some of the superior technology vendors offering affordability assessments, decision engine backed workflows, online portals and two-way customer communication channels. Advanced vendors, such as Telrock, come incorporated into first and third party systems, negating the need for a system integration process.

The business benefit from digital communications is significant. For first party they can increase the number of customers that self-serve, especially on the last day of the month when they get paid — which is traditionally when an inbound call center is at it busiest. These small aggregate gains in customer engagement equate to significant increases in provisioning capital requirements. For first and third party entities, the use of this technology significantly reduces the volume of these now increasingly expensive calls, crucially moving businesses towards more economically viable operating models.

The biggest wins can be delivered by technology such as decision engine-based enabling servicers. These work by specifying rules around acceptable tolerances for repayment plans and terms, which are designed in accordance with the organization’s own risk appetite. Customer journeys are then completely automated and determined by the underlying decision engines, meaning that each customer will receive a completely compliant customer journey — significantly reducing the conduct risk of servicing and the overall costs.

Technology is pivotal to the success of the credit industry in Europe. It is no longer just a ‘differentiator’ between services it is a ‘must have’ commodity that must be adopted if the industry, its organizations and the European financial markets as a whole are to thrive in this new regulatory landscape.

Preston has worked in the collections and purchase industry for both first and third party companies. He currently works with sellers and purchasers in the UK, Ireland and Spain and specialises on the best technology, operating model design and collection strategies against the continuously evolving regulatory landscape in the UK and Europe.

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COLLECTORS WEIGH IN ON PROPOSED CFPB RULES

BY JOSHUA FLUEGEL

T

he CFPB released the Outline of Proposals Under Consideration and Alternatives Considered this past July describing rules that it may implement to be followed by all debt collection entities.

The CFPB then announced this 70-page outline would be scrutinized by a panel of third-party collection establishments 28 days later in accordance with the Small Business Regulatory Enforcement Fairness Act (SBREFA). Among the collection professionals chosen to provide suggestions on behalf of the debt collection industry was Kelly Knepper-Stephens, general counsel and chief compliance officer at Stoneleigh Recovery Associates.

The panel was an eight-hour opportunity for Knepper-Stephens and a select few collection professionals to sit before officials of the CFPB and present sugKelly Kneppergestions to improve the Stephens proposed rules for consumers and collection professionals alike. The selected collection professionals, or small entity representatives (SERs), came prepared, bringing with them detailed descriptions of problems with the rules along with options for how to amend them.

“My written response alone was 43 pages,” Knepper-Stephens said. “Every couple of pages I had recommendations.

I had two or three recommendations, at least, for each rule.”

The recommendations were numerous and echoed the desires of many collection professionals looking for definition and certainty in an often-ambiguous set of regulations. Among the recommendations were requests for safe harbor provisions as protection from FDCPA violations as well as requests for definite dates in the future when rules would go into effect. Knepper-Stephens backed these recommendations with substantial of data.

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“I had a lot of numbers about how some particular regulations would impact my business,” Knepper-Stephens said.

“For example, for the proposed written authorization requirement before you can take a payment on an out of statute debt, I brought data showing that when I send something out to a consumer for their written acknowledgement, I only get four back for every 15 I send out. I have a nonresponse rate of 73%. If I have the same response rate and if I’m not allowed to take a payment unless I have written authorization, then under the proposal, 73% of the time I’m not going to get a payment when I otherwise would have.

“We also came with solutions, ways to change the rule that would still meet the CFPB’s goals and obligations to protect consumers’ rights and interests but also allow small businesses to continue to exist. We came with suggestions across the board for almost every proposal the CFPB had.”

Not only did Knepper-Stephens and company’s presentations make requests for clarity but also for exactly what it is a collection agency or law firm can say or write to a consumer. The panel, as well as the rest of collection professionals, urged the CFPB to provide precise words that can request payment while being safe from legal repercussions. This has been fueled by the CFPB’s tendency to provide tools advertised to keep an agency safe from legal action yet still leading collection professionals into lawsuits; such as a collection letter the CFPB provided.

“I looked at the letter. I think I found at least five places where there were problems in light of existing cases and existing language that courts require to be on letters,” Knepper-Stephens said. “For example, an account that they chose for their sample validation letter is an interest-bearing account. But their isn’t any interest language anywhere in the letter.

There’s a new case in the second circuit,

there’s a seventh circuit case as well, that talks about if the balance is going to change because interest is occurring on the account you need to tell the consumer that. The CFPB didn’t have that language on the letter. The question for the CFPB is: Are they purposefully leaving that language out? Is that a choice? If we use that letter are we safe from lawsuits even though it doesn’t have that interest language on it? Did they forget it?”

Though the preparations for the panel were immense and the quantity of recommendation for the outline great, it was the hope of every SER present that this input would not fall on deaf ears. The proceedings were dictated by law so it was the fear of many that the CFPB’s attendance was merely the signing off of a requirement and nothing more. Fortunately, it appeared to Knepper-Stephens as if the CFPB representatives came ready to listen.

“I thought they were very receptive,” Knepper-Stephens said. “On the panel for the CFPB were Kristin McPartland, Dan Sokolov and John McNamara. John McNamara was a member of our industry before he joined the CFPB. I found that they have always been very open and eager for information that I hope they use to help create a balanced rule. I definitely felt like they were pleased that we had come prepared with a significant amount of data and information about each section of the proposal that we found troubling.”

CFPB Director Richard Cordray’s stated in his remarks for the release of the outline, “We also plan to address first-party debt collectors soon, but on a separate track.” Amidst the efforts to help make a workable set of rules through the recommendations of the SERs, KnepperStephens felt productivity could have been increased greatly if first-party representatives were present at the panel. The relationship of creditors and third-party collectors is largely entwined. An ideal collection scenario involves actions being

November/December 2016

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“The panel, as well as the rest of collection professionals, urged the CFPB to provide precise words that can request payment while being safe from legal repercussions. “ taken by the creditor with the third-party collectors continues and the progress does There has been a significant amount of in mind and visa versa. Taking recom- not stop after the SBREFA panel. litigation about that.” mendations for the outline from third“I think the CFPB is trying to figure Even though the process of enlightparty without first-party present could all that out,” Knepper-Stephens said. “I ening the CFPB on debt collection has possibly nullify progress if first-party were hope they are willing to continue to have seemed like an uphill battle to many to have a conflicting opinion. a dialogue with the SERs who served at collection professionals, it is a process “I wrote 43 pages on how I think the last panel and perhaps solicit feedback that must continue. Knepper-Stephens their proposal is going to impact my from them again once the first-party rules explained that seeking feedback for this business,” Knepper-Stephens said. “If come out.” particular outline is a first step and the the first-party crediCFPB may still be tors say something able to contribute to that I wasn’t anticia positive future for pating it very well the debt collection inmight change my dustry. She said future answer. That’s why steps can also be aided I have been very by collection profesconcerned and asksionals making their ing, ‘Where are the voices heard. creditors, why aren’t “I don’t think they here and what there is any reason are you guys going why they [collection to do about it? I am professionals] should concerned about the keep silent,” Kneppersmall business crediStephens said. “If they tors not being here have comments and to comment and thoughts about the Steven Fuernstahl, Richard Cordray and Kelly Knepper-Stephens at a SBREFA hearing. how their comments proposed rule, I think will likely impact or change my answers.’

Of course the best preventative mea- they should reach out to the CFPB rule“The CFPB indicated that they sures are proactive measures. Had a meet- making team and provide them with inhad to start somewhere and this was ing or panel of some sort with the CFPB formation. The CFPB has been very open how they decided to start. We know and third-party collectors been held before about trying to reach out to industry the CFPB has a first-party team that’s the rules were released, collection profes- members or industry associations. If you working on first-party debt collection sionals might not have felt such a sense of put something together to send to the rules. From the information I gleaned regaining lost ground. Even establishing CFPB, you should also send it to your lothat day at the panel, I think they an- a mutually understood language would cal Congressman. ticipate having a first-party SBREFA have laid a strong foundation for an effec“Unfortunately because of a couple for the first-party rule before the CFPB tive set of rules. bad actors in our business, there is a bad will release the debt collection pro“I do wish that before they had come perception about us. We need to actively posal. It is unclear whether the CFPB out with this outline they would have at end that perception and turn it around so will allow the creditors to comment least presented it to folks at ACA Inter- folks realize we are great businesses. We on the proposed debt collection rule national, DBA International, the CRC keep the economy running.” through a formal SBREFA. For the first- [Consumer Relations Consortium], and party SBREFA, I hope that the CFPB NARCA,” Knepper-Stephens said. “PerCollection professionals can identify will convene a SBREFA panel with first- haps they could have avoided the larger and contact their representatives by visitparty people and debt collectors who problems that they didn’t see. For ex- ing the following websites: collect using an early out strategy. Any ample, using the term “default.” Across Contact Your Governor small business that would be impacted the board, everyone presented that using www.usa.gov/state-governor by the rule should get to comment.” the term “default” is just problematic. I Contact Your Senator Knepper-Stephens seems to hope think the CFPB chose the term “default” www.senate.gov/senators/contact/ most of all that the communica- because it’s a word used in the FDCPA; Contact Your State Representative tion between the CFPB and third-party but it’s not defined in the FDCPA. www.house.gov/representatives/find/ .com

November/December 2016

19

KNOWING REQUIREMENTS FOR HIGH-END COLLECTION SOFTWARE

BY JOSHUA FLUEGEL

A

collection agency with more than 1,000 seats has a hefty list of requirements for its collection software. This list of requirements can include seamless data storage and retrieval, easy integration with other software the agency is using and of course the litany of regulatory requirements. It can be difficult to prioritize the requirements as the neglect of any of them could lead to a crippling work stoppage. The importance of talking with software vendors cannot be overstated. Whether a collection professional is talking with their software partner of 10 years or a prospective vendor on the eve of the big collection software purchase or understanding what features are available and receiving an objective evaluation of what an agency’s software needs are, communication with the vendor can help any agency make a wise purchase.

“A feature of specific benefit to high-end collection operations is the ability to stream realtime collection transactions and events to execute predictive analytics in-stream and provide Ed Wallen immediate operational insights,” said Ed Wallen, vice president of FICO. “The obvious use cases for large call center operations are around optimizing and predicting collector activities, payment events, dialer interactions, and placements to external servicers. However, an ever-increasing benefit of streaming analytics can be applied to a wide array of compliance use cases, for instance having the ability to not only detect anomalous behavior and forecast call velocity on specific individuals and phone numbers but to also be able to react in real time, thus short-circuiting

20

potential compliance violations. The organizations that take a comprehensive approach to solve for today’s regulatory environment while focusing collection efforts by leveraging predictive analytics will be the most successful.”

“The stakes are high for large debt collection agencies. Such high stakes must be met with large efforts to work with software vendors to make sure the product used meets all the agency’s needs.”

As no two collection agencies are the same size, a software solution must have the ability to mold itself to the agency, improving any surplus or shortfall of staff.

“System flexibility allows for high-end users to transform their system to fit their business and software architecture needs,” Lex Patterson, president of DAKCS Software Lex Patterson Systems. “Flexibility combined with an adaptable API, allows for agencies with various amounts of IT staff to maintain control over their data and software environments. Customizable workflow processes offer a solution for businesses meeting clients’ unique configurations and requirements.”

Ron Fauquher, CEO and co-founder of Ontario Systems said it has never been more important to collection professionals to remain compliant with the Ron Fauquher TCPA and the regulations of CFPB. Fauquher said this compliance could be easier to maintain if an agency’s collection software infused the abilities of a contact management solution in order to stay on top of state calling restrictions. This functionality could also expand by providing middle and upper management with performance score cards for the various caller activities.

A great deal of work is being done at a rapid pace on the collection floor of a large collection agency. If changes must be made, they must be made quickly to maintain optimal efficiency. Fauquher stated software for a large collection agency should have the ability to adjust workflow in real-time as to not head down the wrong path longer than is necessary.

The stakes are high for large debt collection agencies. Such high stakes must be met with large efforts to work with software vendors to make sure the product used meets all the agency’s needs.

HIGH-END COLLECTIONS SOFTWARE DAKCS Software Beyond ARM FICO Debt Manager Solution Ontario Systems Artiva

November/December 2016

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HIGH-END COLLECTIONS COMPARISON CHART GENERAL FUNCTIONALITY

Artiva

Beyond ARM

FICO Debt Manager Solution

Separate collection database/normalized database

Yes

Yes

Yes

Subclients can be consolidated with master client to produce a consolidated statement

Yes

Yes

Yes

Generates customizable correspondence on demand

Yes

Yes

Yes

Automated letters by client with flexible triggers

Yes

No

Yes

Automated faxing

Yes

Yes

Yes

Integrates with email

Yes

Yes

Yes

Automated phone dialing

Yes

Yes

Yes

Goals feedback in real-time

Yes

Yes

Yes

GUI environment

Yes

Yes

Yes

Web access: Secure and customizable remote access for collectors

Yes

Yes

Yes

Web access: Secure and customizable remote access for debtors

Yes

Yes

Yes

Web access: Secure and customizable remote access for clients

Yes

Yes

Yes

Generate an individual status report for an account (or linked accounts)

Yes

Yes

Yes

Application development studio

Yes

Yes

Yes

Built-in collection agency templates

Yes

No

Yes

Integration with Crystal Reports

Yes

No

Yes

User-defined account matching criteria

Yes

Yes

Yes

User-defined balance buckets

Yes

No

Yes

Ability to extend the account and related tables

Yes

Yes

Yes

User-Defined payment types

Yes

Yes

Yes

Configurable account flow

Yes

Yes

Yes

Artiva

Beyond ARM

FICO Debt Manager Solution

Pre-charge-off collections

Yes

Yes

Yes

Post-charge-off recovery

Yes

Yes

Yes

Agency/attorney management

Yes

Yes

Yes

Asset sales

Yes

No

Yes

Metro2 reporting on post-charge-off

Yes

Yes

Yes

System of record or nonsystem of record functionality

Yes

Yes

Yes

Repossession tracking

Yes

No

Yes

Bankruptcy/deceased management

Yes

Yes

Yes

RECOVERY FUNCTIONALITY

Work by accounts or people (person- vs. account-centric)

Both

Both

Both

Artiva

Beyond ARM

FICO Debt Manager Solution

Disputes/deduction codes can be assigned

No

Yes

Yes

Identifies and tracks problem invoices

No

No

Yes

Coded problems separate from other receivables

No

No

Yes

Offers customer and invoice-level notes

No

Yes

Yes

Electronically reproduces/transmits invoices

No

Yes

Yes

PRE-CHARGE-OFF FUNCTIONALITY

TELEPHONY FUNCTIONALITY

Artiva

Beyond ARM

FICO Debt Manager Solution

Dialer

Yes

Yes

Yes

Fully integrated dialer

Yes

Yes

Yes

Real-Time read/write access to application database

Yes

Yes

Yes

Unattended messaging

Yes

Yes

Yes

Call blending

Yes

No

Yes

Carrier grade hardware (Nebs compliant)

Yes

No

Yes

Automatic remote error reporting

Yes

No

Yes

Automatic software/firmware updates

Yes

No

Yes

•

All systems permit related accounts viewed simultaneously, customized formatting of statements, will set up clients as either gross or net remittance, statements can be regenerated for a specific period, and each system tracks multiple internal and external contact names/numbers.

• All systems have agency functionality for trust accounting, complete client activity statement history and user-defined collection tasks.

• All systems have external vendor/service integration for automated service requests based on collection strategies, automated collection strategies based on returned data and processes check and credit card payments interactively.

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.

IVR CONTINUES TO RESOLVE DEBTS

T

ried and true methods of contacting consumers to collect debt continue to be poked and prodded by increasing demands made by compliance.

One of these many methods is the use of an interactive voice response or IVR. Though regulators’ efforts to improve the consumer’s position in debt collection have thrown IVR users a few curveballs over the years the method is still used and is still effective.

“Utilizing an IVR provides agencies with a cost effective and compliant avenue for consumers who are willing and able to quickly make payments without huR. Fred Houston man intervention,” said R. Fred Houston, president and CEO of Columbia Ultimate. “IVRs can process payments in a secure environment and provide account information and details without the need to spend the agent’s valuable time. Additionally, IVRs are programmed to always maintain compliance with disclosures and privacy, preventing any human error in dealing with consumer account information. More and more consumers are accustomed to using self-service options to manage accounts and it frees up agent time for additional accounts. It’s a win-win.”

Making the appropriate adjustments and modifications to an IVR can increase chances of collection while decreasing chances of a lawsuit. These adjustments can range from call times to scrubbing cell phone numbers.

“Consistent automated contacting is the key to collecting from consumers today,” said Jeryl Smith, outbound technology expert at IAT, an Enghouse Interactive Company. Being Jeryl Smith very careful to not call cell phones with automated dialers without express written

22

approval, contacting consumers can still be done and be effective. There are databases that can be used to avoid calling assigned cell phones and ported phone numbers to cell phones. These accounts with known cell phones can be isolated onto campaigns for manual contacting.

Databases can be maintained to identify which accounts have given permission.”

As IVR technology has been in use for some time and by multiple industries, consumers are familiar with its use. It is believed that some consumers prefer resolving the debt without human interactions in favor of a sense of privacy. Those in need of a conversation with a collection professional can also be obliged by an IVR solution.

“Most consumers are understanding when debt recovery companies make automated calls, said Smith. “The IVR technology should provide the ability to correctly identify the called party.

The balance owing can then be disclosed, and a non-human option given to satisfy the debt through an electronic payment provider.

Not only can an IVR make a consumer feel more comfortable but it can also enhance security, protecting the agency from possible mistakes.

“IVR also is effective helping your agents complete payments,” said Tim Schriner, CEO or RevSpring. “Once an agent and consumer agree on a payment – Tim Schriner whether a PIF (paid in full), SIF (settled in full) or a payment arrangement – the agent transfers the consumer to the IVR. The consumer uses the telephone keypad to enter their account information and electronically sign the payment agreement. Security increases as the agent does not hear or see the account number. Furthermore, since the consumer does not speak the account number, the risk of it being overheard

BY JOSHUA FLUEGEL

is eliminated. The IVR also enables the consumer to immediately provide the electronic signature required by Reg. E for payment arrangements.”

A collection manager cannot be everywhere at once so keeping tabs on all collectors can be difficult. An IVR can help manage collectors by controlling the communication. The key is to know and control the IVR settings and communication.

“Control is key to a more compliant IVR,” said Kerry Sherman, vice president business development at TCN. “Agencies cannot control everything that their Kerry Sherman agents say or promise within the regulatory guidelines. Know what message is being delivered as outbound and inbound calls are made.”

Sherman elaborated about his visit to a healthcare finance convention. In learning of the concerns specific to the healthcare field he commented about how prepared the collection field makes technology for the others. The experience brought him to the conclusion that, “debt collection is the mixed martial arts of the dialer world.” Such a tough environment means technology will need to continue pressing forward and evolving.

Only with an effective collection process will collection professionals be able to harness this IVR power and continue to thrive.

IVR COLLECTIONS SOFTWARE Columbia Ultimate IAT RevSpring TCN

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WHAT IS NEW IN VIRTUAL COLLECTIONS?

BY JOSHUA FLUEGEL

A

utomation has been known to produce a great return on investment.

It turns the repetitive monotonous tasks into nearly instantaneous events that require little to no intervention. The trick is to perfect the automation. This is a journey collection professionals have been on for some time. How does one recreate the consumer experience without a collection professional on the other end of the interaction?

Over the last several years, advances have been made in technology and vendors have altered products to better address the regulatory and operational obstacles collection professionals face on a daily basis. Step-by-step virtual collection technology moved closer to what consumers and collection professionals would agree is a preferable account resolution experience. Several virtual collection vendors weigh in to describe where the software capability is today.

“There have been a number of recent updates to our Virtual Agent,” said Matthew Hill, president and CEO of The InterProse Corporation.

“We have added WeMatthew Hill bAR Analytics dashboards to provide in depth consumer metrics to determine when and how consumers are paying. Armed with this information the agency can construct campaigns to optimize consumer behavior. We have also added live chat capability if the consumer wishes to chat with an agent during their session.”

By working with collection professionals, vendors understand what it meant to be a compliant collector. They also increase their understanding of the collection process and what information a professional needs at his/her fingertips to make sure collection activities are running optimally.

“PayStream has been a major focus in our development efforts in the past 18 months, with over 10 software releases,” .com

said Michelle Jeffers, VP of business development at Applied Innovation.

“Compliance, customer feedback and increased agency profit potential drive development and Michelle Jeffers are the main considerations in prioritizing what we do. We have added advanced algorithms to increase the highest possible payment amounts. In cases of partial payment, you can direct the consumer to create an additional arrangement to satisfy the balance in the future.

Recurring payments and settlements have lockdown features preventing manipulation of the system in attempts to attain the lowest possible payment.

“The new settlement protection feature will not offer a settlement in certain circumstances if the consumer actions indicate you have the opportunity to receive payment in full. Virtual collector workflows mimic those of live collectors. PayStream users have a different experience based upon ‘wizard’, configured by any combination of status code, client code, balance, etc. Agency users can now set up payment plans in the admin portal allowing for automation of recurring payment reminders – no more mailing! In addition to the virtual collector, you now have an express pay page that does not require authentication.”

Take the time to speak with your virtual collection software provider. It is in their as well as your best interests to voice your needs on the collection floor. Only through a continuing dialogue will virtual collection software surpass the level of performance collection professionals need to satisfy clients and consumers.

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WHAT TO AVOID WHEN IMPLEMENTING ELECTRONIC PAYMENTS

BY JOSHUA FLUEGEL

S

o long as accepting a payment from a consumer is in a collection agency’s collection process, a successfully implemented electronic payment solution is a must. However, there are many missteps taken by collection professionals when selecting and integrating the system. In an effort to reduce the number of obstacles between collection staff and a paid account, be informed on current electronic payment technology and avoid a few common mistakes.

“Credit/Debit Card and ACH are two completely different types of transactions,” said Bonnie Finley, chief sales officer at EFT Network. “Agencies need to Bonnie Finley know who is on the back end and if they are keeping their transactions compliant and secure. In the world of ISO, sub ISO’s and reseller of a reseller it’s difficult to peel back the onion. However, understanding this is vital and is often overlooked until it is too late.”

“Many times an agency doesn’t do a thorough due diligence on the provider,” said Robert Pollin, president of Autoscribe Corporation. “You must ensure the security and compliance of any provider considered.”

“Quite simply, a strong end-to-end payment integration means that payment data is never stored locally on a merchant’s servers and should allow for real time acceptance, authorization and processing all without ever writing down card info or batching payment files,” said Michael Loscavio, president of PaidSuite. “We recommend that merchants review their payment practices quarterly to ensure proper integration, training and process - a good payment vendor

24

should be more than willing to help you with these audits.”

“An important consideration when shopping for an electronic payment solution is to consider the work flow for your staff,” said Dawn Updike, customDawn Updike er success manager at PDCflow. “Does the payment solution create a user friendly and simplified work flow? Does it include compliance considerations that are unique to the collections industry? Does it offer online payments or IVR services? Especially for the collections industry, a payment solution that offers the path of least resistance to allow for inbound payments is going to increase revenue.”

If a great deal of work has been done to make sure an electronic payment portal functions according to regulations and an agency’s needs, it must be assured the consumer can reach and use it easily.

“It is critical to prominently include the portal on all consumer-facing communication,” said Tim Schriner, CEO of RevSpring. “After investing in an online portal, you need to make certain consumers know it exists and find it easy to access. For example, your organization could place a “Pay My Bill” button on your website home page, include the portal address on your hold messages, use a hyperlink on your email and SMS communication as well as make clear call to action on your printed communication directing consumers to the portal.”

“I think that a common mistake by agencies is that ‘if you build it they will come,’” said Matthew Hill, president and CEO of The InterProse Corporation.

“They don’t. Not without some help.

The agency needs to “market” to the consumer using as many channels as possible. The payment portal URL needs to be easy to remember, highlighted on all correspondence, added to music/message on hold and added to the corporate website.”

Though not the most important aspect of an electronic payment solution, cost tends to dominate a collection professional’s attention. Be sure to fully understand precisely what is being provided and what is being purchased.

“Ask about the difference between merchant, processing and web transaction fees,” said Michelle Jeffers, VP of business development at Applied Innovation. “Vendor offerMichelle Jeffers ings differ greatly; be sure to know what you are comparing.”

This article is continued on www.CollectionAdvisor.com.

ELECTRONIC PAYMENTS SOFTWARE Applied Innovations APS (Powered by PayScout) Autoscribe Corporation BillingTree EFT Network InterProse Corporation PaidSuite PDCFlow RevSpring

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November/December 2016 Volume 16, No. 6 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 Production Andrea Bergeron Paul andrea@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. ©2016 All Rights Reserved Magazine Publishing Group, Inc. Printed in the U.S.A.

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