January/February 2016 Buyers Guide Issue

DEBTCOM PLIAN BUYING

CE ISSUE&

Using Technology to empower

Helping Debtors Find the Money Front Line Compliance Solutions Determining Meaningful Involvement The Life of a Legal Collection Solution The Year in Review: Enforcement Actions Understanding the Social Security Number 4 Compliance Areas Debt Buyers Must Address

Jan/Feb 2016

Vol. 16, No. 1

Dennis J. Barton III

Avoiding bait ‘N’ Sue Blues

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

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Compliance & Debt Buying

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with training tools

4 Debra J. Ciskey 6

Nick Jarman

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Harry A. Strausser III

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Ron Brown

14 Sam Edens 16 Fred N. Blitt 10 T. Steel Rose, Editor

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appy New Year from all of us here at Collection Advisor! We here at Collection Advisor like to start off the year thinking about the one thing that should be on top of every collection professional’s new year’s resolution list: compliance. To help you start the year right this issue features numerous articles on compliance and CFPB developments. One such article is this issue’s Law Firm Spotlight where we speak to Dennis J. Barton III about his work with the Barton Law Group and what he recommends collectors do to avoid being baited into a lawsuit.

In this issue Benchmark Advisor Harry A. Strausser III rallies the troops and calls collection professionals around the country to take action and positively influence the current collection environment. Agency Advisor Nick Jarman discusses some front-line compliance issues agencies commonly face and suggests ways to deal with them. As your Cash Flow Advisor, I explain a few ways collection professionals can help debtors find the money to close their account and create a win-win situation. In light of the FDCPA becoming middle aged a few months ago, Compliance Advisor Debra J. Ciskey takes a moment to reflect on its developments and debt collection enforcement actions. Skip Tracing Advisor Ron Brown analyzes the one thing every American has…a social security number. He discusses the system’s history and what information can be derived from this powerful form of identification. Technology Advisor Sam Edens covers debt buyers and the four compliance areas they need to master. Legal Collection Advisor Fred N. Blitt helps define what it means to be meaningfully involved according to the FDCPA. Next issue Collection Advisor will take a closer look at legal collections. Until next time, we look forward to hearing from you.

T. Steel Rose CPA, ACS Editor

editor@collectionadvisor.com

Checklists and Training Tools

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January/February 2016

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USING TECHNOLOGY TO EMPOWER COLLEC TIONS www.CollectionAdvisor.com

January/February 2016

Advisors

Volume 16, No. 1

Features

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Compliance Advisor

The Year in Review: Enforcement Actions Debra J. Ciskey

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Complete Paper Trails Boost Collections CONTRIBUTED BY THE IACC

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CFPB News Desk

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COLLECTION agency Advisor Front Line Compliance Solutions Nick Jarman

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Benchmark Advisor

CFPB Revises Appeals and CFPB Debt Collection Rules Update

Agency Spotlight Dennis J. Barton III, managing attorney of The Barton Law Group

Pull On Your Boots and Get Back to Our Roots!

Harry A. Strausser III

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Talking Like Movie Heroes

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CFPB Advisor

Helping Debtors Find the Money

T. Steel Rose

The Life of a Legal Collection Solution

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SKIP TRACING Advisor

Understanding the Social Security Number Ron Brown

4 Compliance Areas Debt Buyers Must Address Sam Edens 16

Legal COLLECTION advisor

Determining Meaningful Involvement Fred N. Blitt

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2016 Collection Resource Directory

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Technology Advisor

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JOSHUA FLUEGEL

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JOSHUA FLUEGEL

Legal Collection Software Checklist

JOSHUA FLUEGEL

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Collection Advisor’s

2016 Collection Resource Directory

TRAINING TOOLS AND CHECKLISTS January/February 2016

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Collections Skip Tracing Data The more complete your information, the more successful your business.

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Year in Review:

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The FDCPA is becoming middle-aged; it saw its 38th birthday on September 20, 2015. On the day that President Jimmy Carter signed the FDCPA into law on September 20, 1977, the number one hit song was “Best of My Love” by The Emotions, and Kenny Stabler was on the cover of “Sports Illustrated.”

Many of us take a few minutes on our birthday to review the last 12 months of our life, maybe to say a prayer of thanksgiving for that year, and to set a few goals for the year ahead. With a nod to Edmund Burke’s sage advice: “Those who don’t know history are doomed to repeat it”, let’s take a look back at developments under the FDCPA and debt collection enforcement actions that occurred in the last year.

Enforcement: Lessons Learned

CFPB and the FTC have finalized more enforcement actions this year than we have seen in the recent past. I put them in two categories—those related to the practices of legitimate industry participants, and those conducting scams under the guise of debt collection. The scammers create havoc for legitimate debt collectors because they cause consumers to be suspicious of anyone claiming to be a debt collector; and the fact that regulators treat them like debt collectors and not like criminals doesn’t help.

Bringing actions under the FDCPA and levying civil penalties that are likely to go unpaid will not stop fraudsters. Bringing criminal actions resulting in prison time just might.

These actions are representative of the enforcement actions taken and are not all inclusive. In the scammer, or fictitious debt collector category, we saw the following enforcement actions related to the practices described here: ■■ Pretending to be a state or district attorney when collecting bad checks, making false threats of criminal prosecution, deceiving consumers into paying extra for a financial education class. CFPB, 3/30/15: National Corrective Group, Victim Services, Inc., and American Justice Solutions, Inc. ■■ Making false claims of authority to collect fake debts, repeatedly calling consumers who have requested calls to cease, making calls at inconvenient times or at a consumer’s place of employment with knowledge that such calls are prohibited by the employer, calling multiple times in a day

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Compliance Advisor Debra J. Ciskey

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with such frequency as to constitute harassment. Threatening wage garnishment, threatening to have consumers’ drivers’ licenses revoked, threatening legal proceedings, or threatening arrest or imprisonment. FTC, 4/6/2015: K.I.P., LLC et al Attempting to collect debts that don’t exist, frightening people into paying them with false threats of arrest, wage garnishment and “financial restraining orders.” This order implicated dialing and payment processing vendors who were accused of turning a blind eye even when circumstances may have indicated that there were problems related to the practices of the scammers. CFPB, 4/8/2015: Universal Debt and Payment Solutions, et al.

Actual debt collectors or entities collecting their own debt were sanctioned for stepping over the compliance line as well: ■■ Misrepresenting their identity by altering caller ID information, making it appear that calls are coming from the repo man, pizza delivery companies, flower shops, vehicle storage facilities or family and friends. Equally deceptive, making it appear that calls were coming from a law enforcement agency and stating or implying that criminal charges are about to be filed. Further, discussing defaulted loans with consumer’s references, employers, friends, and family members, and hiring a repo company to make calls when there is no intent to repossess or when repossession is not imminent. CFPB, 10/1/2015: Westlake Services and Wilshire Consumer Credit ■■ Sending threatening or deceptive text messages and emails to consumers which threatened to arrest or sue consumers.

Contacting consumers’ friends, family members and employers about debts. Withholding information a consumer January/February 2016

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“More enforcement actions are detailed on the FTC and CFPB websites. “ Ciskey - Continued from page 4

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may need to dispute his debt. Withholding the fact that your communications are from a debt collector.

FTC, 5/21/2015, Unified Global Group, et. al.

Collectors claiming or implying that they are attorneys, or that they work for an attorney, in an effort to convince a consumer that a lawsuit is imminent. Misrepresenting that a lawsuit has been filed or that wages, bank accounts, or 401k accounts will be garnished or seized. FTC, 1/20/2015: Commercial Recovery Systems, Inc. Falsely claiming to be a law firm, process server, or government-affiliated entity, or an attorney or investigator.

Using phone numbers with different area codes to deceive consumers

about their identity. Falsely representing that a consumer is subject to imminent arrest that day, or within hours or even minutes, and would be subject to spending months in jail. Contacting third parties about the purported debts, warrants, and charges. Withholding information related to the fact that they were a debt collector and failing to provide the required notices and disclosures required by law. Adding unauthorized processing fees to payments made by credit card. FTC, 1/5/2015: Vantage Point Services, LLC et al.

More enforcement actions are detailed on the FTC and CFPB websites.

The value in reading and understanding these consent orders is that we can surmise where the CFPB might be considering

Industry • Regulators • Consumers

related to its rulemaking for debt collection; and they identify practices that are sure to trip red flags with enforcement teams. For example, several actions included the use of manipulated caller ID information. It might be worthwhile to examine your policies and practices related to that practice now. Other actions related to the addition of convenience fees. Other common themes relate to the failure to send required notices, such as validation notices, and failing to disclose that communications were from a debt collector. Do you have policies and procedures in place to ensure that these key compliance requirements are in place?

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.

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January/February 2016

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Front Line Compliance Solutions

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Chances are right now someone within your organization is evaluating or strategizing how to remain compliant with federal and state regulations while still performing at a high level and being profitable. Most affected when it comes to compliance are the collectors that must overcome the sometimes burdensome regulations and ultimately execute the developed strategy while providing the desired results. This article discusses some common front-line compliance issues faced by collectors during the collection process and suggestions on how to deal with them.

Consumer Identification

The first thing a collector is required to do on a collection call when speaking with an individual is confirm the identity of the consumer. This has become increasingly difficult for collectors.

Of course it is essential for a collector to confirm they are communicating with the consumer of record and the appropriate steps are taken to confirm. A concern is what those appropriate steps should be. Confirming the consumer’s first and last name should be a must, then another point of verification such as the last four digits of the consumer’s social security number, date of birth, or address on file could be used. Furthermore, there is an additional concern of how this process of identification should be verified. Should the collector provide the information and the consumer confirm it or should the collector request the information from the consumer and then the consumer provides it? While this is a necessary and reasonable process, consumers concerned about identity theft and fraud are becoming increasingly less likely to provide or confirm this information which ultimately ends that collection call attempt due to the collector being unable to confirm the consumer’s identity.

A solution would be to create an Identification of Consumer policy that outlines the company’s requirements and then manage to it. The policy could provide collectors with detailed steps about which information may be used in the confirmation process and whether or not the collector may provide the information for the consumer to confirm or vice versa.

Disclosures

Once the consumer has confirmed their identity and the collector is comfortable they are speaking with the consumer of

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Collection Agency Advisor Nick Jarman

record, disclosures must be communicated to the consumer.

Disclosures vary based on federal and state requirements in addition to company policy, with the two most common disclosures being the mini-Miranda and call recording. The main issue here is the length of time the disclosures take to say and then ensuring the disclosures are stated verbatim. The amount of time taken to identify the consumer properly and then communicate the disclosures is more time the collector is not talking about the resolution of the debt and thus provides the consumer with more opportunity to terminate the call early.

While disclosures are frustrating for collectors, they must understand they are required and there are no short cuts around them. A call opening script could be developed to assist the collector with the most efficient way to identify the consumer and provide the disclosures without losing the attention of the consumer. We only get one chance to make a first impression.

Full and Complete Information

If a collector is fortunate enough to have the consumer confirm their identity, provide the required disclosures, and proceed with the collection call then at some point an attempt to obtain full and complete information from the consumer will be made.

Full and complete information includes but is not limited to the consumer’s employment, correct mailing address, and alternate contact phone numbers. Consumers are also reluctant to provide this information due to privacy, ID theft, or fraud concerns which create another issue for collectors as they progress in their conversation with the consumer.

Collectors should request full and complete information based on the company’s policies and procedures and remain in compliance with federal and state regulations. It is important collectors understand a consumer’s reservation to provide this detailed information and be empathetic to the concern. Simply because a consumer refuses to provide full and complete information doesn’t indicate they will not resolve their debt. Therefore if January/February 2016

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“One rule of thumb when it comes to compliance would be for every one thing you tell a collector they can’t do, give them two things that they can.”

Jarman - Continued from page 6 the consumer refuses this information the collector should respect the consumer’s decision and continue to progress the collection call in an attempt to resolve the debt.

Lack of Continual Training

Do this, do that, don’t do this, don’t do that. In the fluid legal environment the debt collection industry is in, the previous sentence could sum up what collectors hear these days. In order for collectors to avoid this confusion they need not only to be informed but also trained and coached on how to collect in accordance with company expectations. It is very easy for management to tell a collector what they can’t do, but it’s much more productive for management to tell collectors what it is they can do. One rule of thumb when it comes to compliance would be for every one thing you tell a collector they can’t do, give them two things that they can.

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Training should be consistent and continual for all collectors regardless of tenure.

Company vs. Client Requirements

Each company most likely has its own requirements relating to compliance and collection processes. At the same time, clients will also most likely have them as well. Chances are good the companies and clients requirements are not the same.

While the basis of these requirements may be similar, there could be distinct differences as well. If a company segregates each client with dedicated collection teams, adopting specific client requirements in with company requirements is much easier. However, if a company combines multiple clients with multiple teams, then the varying requirements from clients could pose a significant risk to remain in compliance with each of the different clients.

With many companies doing more

with less these days, there is a good likelihood of multiple clients being worked together. Developing a “most stringent” policy in regards to requirements could reduce the risk of compliance violations. “Most stringent” refers to reviewing each client’s requirements and when it comes to certain aspects of policies or procedures, adopt the most restrictive one and build from there.

Whether it is your compliance, quality assurance, or operational department who is developing strategies and lessons on dealing with compliance, always bear in mind it is the front line collectors who are affected most. Take the time to discuss with your collectors what issues are affecting them and allow them to be a part of the process. The better you understand their issues, the better you will be able to resolve them.

Nick Jarman is COO at Delta Outsource Group, Inc. He also serves on the Board of Directors for ACA International.

January/February 2016

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Pull On Your Boots and Get Back to Our Roots!

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Benchmark Advisor

The proverbial question: “If a tree falls in the woods and no one is around to hear it, does it make a sound?” Mankind has debated this topic for generations. Philosophically, we can argue Harry A. Strausser III many responses to this query. Perhaps no one will ever really know the answer. But with certainty we do know that trees fall every day. We have no ability to stop this process and whether programs attendees ask, “What is leadership in our industry we are there to bear witness to the crash, or not, the process doing about the mess we’re in right now?” If you ask this continues perpetually. question then you are not properly informed. If you wonder This scenario is quite similar to the current regulatory and if you personally, or your firm/department is doing enough compliance environment within to make a difference, then you the collections industry. No mathaven’t reached out to truly unter what sector of the industry you derstand the issues and obstacles “Without the action of many, may work in, first party or third, that need attention. we have suffered through an onWhat can you do to help with our industry will suffer slaught of new aggressive regulatopositive change? Will your boots a continued unsettled, problematic ry agencies, problematic state and on the ground really make a differfederal legislation, and predatory ence? Imagine yourself walking in culture challenged by only a few law firms determined to continuthe woods. It is only you walking lone voices.” ally badger good operators. This on untouched beautiful grounds. insanity has got to stop and will After several hours of enjoyment only do so with the positive enerof the serenity you decide to return gies properly focused by industry to where you started. But there is players. Pull on your boots, join hands, and get back to your no pathway. No sign that you or anyone has been there. Now roots…or stop complaining! imagine 1,000 hikers following you on that same walk. There Business associations across the US, including ACA In- are many boots on the ground. Not just today but every day they ternational Inc., the trade association of credit and collection make that same journey between towering trees, around rock professionals, have been desperately campaigning to obtain the obstacles and over picturesque streams and fields. In no time valuable assistance of business operators in a movement to affect there will be evidence of a path, a clear indication that someone change and pave a smoother pathway for our industry. Local has been here before. Obvious evidence for those that follow in chapters of these groups continue to lament the apathy of mem- the weeks, months and years to come that, “someone has walked bership and declining number of participants at organizational down this path and I now know clearly where to head and from meetings. Everyone is concerned but few are engaged in proac- where we have come.” This is the very core concept of grass tive actions that can make a difference and assure the continua- roots movements that make a difference and drive change over tion of the invaluable services we offer to the business commu- time. Without the action of many, our industry will suffer a nity and economy overall. continued unsettled, problematic culture challenged by only a Often as I attend industry meetings and conduct training few lone voices.

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“Become active in local/regional chapters of ACA and join forces with your regional colleagues.”

Strausser - Continued from page 8

What Can You Do Today?

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ontact ACA International, Inc. at C www.acainternational.org and inquire about how you can become involved on a local and national level. ecome active in local/regional chapB ters of ACA and join forces with your regional colleagues.

I nteract with trade associations in the medical, financial, telecom, and other industries to understand their similar concerns and initiatives that may mirror ours. ontact your state and federal legC islators, let them know you are a constituent, and express your busi-

ness concerns for the difficult environment in which we are forced to operate.

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e responsive to industry “calls to B action” and write letters, make calls to colleagues to engage their assistance and ask, “What can I do to help?”

I was recently working at my weekend home and had to move a very large slab of marble that was serving as a tabletop. I attempted to move the top alone and couldn’t budge it an inch. With the help of one other, we were able to lift each end but couldn’t walk with it. A third person offered help and the two on one side were ok but the sole

lifter on the other struggled. Then appeared the fourth helper and with ease we moved the tabletop. It just took that one other person, that extra effort. There is strength in numbers to reach success.

Pledge to be part of this industry’s heavy lifting today by placing your boots on the ground and taking the steps necessary to be part of the pathway to a better business environment.

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.

One vendor. All the solutions.

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January/February 2016

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Helping Debtors Find the Money ROUTING SLIP Initials

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I had a lunch meeting with several financial advisors this week.

A few lamented how their clients are not able to maintain a budget to live below their means. They mentioned the temptation to use credit cards was too great and the resultant high interest rates only exacerbate the problem. When I mentioned peer-to-peer lending sites to reduce their annual percentage T. Steel Rose, Editor rate by 10% they stared at me in disbelief, like it was too good to be true.

These types of loans accounted for $5 billion in loans last When working with consumers, there are some distinct adyear. The question is not as much, when does it makes sense to vantages to using Lending Club and Prosper worth considering: use peer-to-peer lending to refinance existing debt, but knowing ■■ A fixed rate of interest is probably one of the most compelthe costs involved. Regulatory and compliance considerations ling advantages. may provide an option for cash strapped customers. Accord-  The term of the loan from major social lending sites is either ing to “The Economist” the rapid progress suggests big banks three or five years. and credit-card companies may  There is no pre-payment penbe disrupted in the same way taxi alty. Customers can always “There are some distinct advantages companies have been disrupted by pay off loans early without Uber. The major platforms, Lendpre-payment fees. The applito using Lending Club and Prosper ing Club and Prosper, offer online cation process is fairly easy. worth considering.” loans of up to $35,000 for three  The online application can to five year notes. Chicago-based take just a few minutes to Avant also offers personal loans up to $35,000 funded by insti- complete and a decision on the loan occurs quickly.

■■ tutional investors.

Once they have a loan, monthly payments are automatically Companies like Social Finance emphasize student loans deducted from their checking account. and mortgages as they are pitching student lending services. San ■■ Unlike a home equity line of credit, the loan is not secured Francisco-based lender, Earnest, uses an algorithm and 80,000 by your customer’s home. While they are obligated to repay to 100,000 data points to lend money to students with little to the loan, they are not secured by any of their assets. no credit history.

This list goes on. LendingHome, another San Francisco The general requirements borrowers must meet to qualify start-up, offers mortgage loans and allows accredited investors for these loans include: to participate with at least $50,000. Los Angeles-based AssetAv- ■■ Must be a U.S. citizen or permanent resident. enue targets non-owner occupied, first lien, mortgage loans, and ■■ Must be 18 years old with a valid bank account and a valid is open to accredited investors in a few states.

Social Security number.

The point is trying to help a customer by making them ■■ Must have a FICO score of at least 660. aware of options is always a good idea. For small balance cus- ■■ Their debt-to-income ratio (excluding mortgage) must be below 35%. The total of monthly debt payments (e.g., tomers, San Francisco-based LendUp offers up to $500 for credit card, school loan, car payments) divided by monthly 35 days at 272.73% APR (as of October 22, 2015). While it income must be less than 35%. is clearly exorbitant to the point of being predatory, their stated mission is to help people establish credit who don’t have ■■ At least three years of credit history, showing no current Continued on page 15 standard creditworthiness.

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CFPB Advisor

January/February 2016

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Complete Paper Trails Boost CollectionS

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new International Association of Commercial Collectors (IACC) survey, “What I Wish My Clients Knew, What I Wish They Told Me,” suggests that by closing any gaps in recordkeeping and consistently following credit and collection procedures, commercial creditors would eliminate some of the biggest obstacles to collection.

IACC electronically administered the survey to its members – all of whom are commercial collection professionals - in October. The goal: Identifying actions commercial creditors should and shouldn’t take to ease both in-house and third-party collections.

Nearly 37% of survey respondents chose missing records as the greatest barrier to successful debt collection. “Documents detailing what the debtor ordered, and what was delivered and when, are commonly missing from the information a commercial collector receives,” said Joe Batie, chief commercial officer at Caine & Weiner in Woodland Hills, CA, in a post-survey interview.

“This creates an unnecessary dispute for the debtor that the balance that is placed for collections is wrong, and allows the debtor to prolong the collection cycle.” said Al Watson, national collections manager at Altus Global Trade Solutions in Kenner, LA. Batie conservatively estimates that 55% to 60% of clients provide his company with incomplete records. Ironically, pressure to save money contributes to the missing document, money-losing situation, he said. “Companies are trying to give good service, keep prices down and be profitable. So they either don’t hire as much administrative help, or they hire less experienced help and hope they’ve found a diamond in the rough.”

Sometimes the documents were never generated, he said. “Sometimes the information may be there, but no one has time

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to go and find it for us,” he said.

Two Collectors are Not Better Than One

Nearly a third of the IACC members who took the recent survey identified the hiring of multiple collectors to pursue the same debt as the biggest roadblock to successful collection.

Usually, the doubleteaming is not intentional, but is also tied to gaps in record keeping. “We have seen clients place accounts with competing agencies to put pressure on debtors (but) it appears that poor record keeping may be the biggest culprit,” said Altus Global Trade Solutions Manager Rose Hill. “This would include lack of communication inhouse between client contacts, where one places the account but another wants it kept in house.”

“At times, more than one collections professional is working the same account because a client isn’t familiar with, or isn’t following, the Triadic Rule,” Batie said. The Triadic Rule is the collections organizing principal that says a creditor contacts a collections agency, and the agency will bring in an attorney if necessary.

However it happens, it never makes the process go more smoothly. “One person could be demanding payment in full, and then someone else calls and agrees to a protracted payment arrangement,” Batie said. “Of course debtors are going to go for the protracted agreement even if they have the ability to pay in full. The frequency of debtor contacts by multiple collectors not aware of the others’ efforts can also result in a harassment complaint,” he said.

Contributed by the International Association of Commercial Collectors. For more information, visit www.commercialcollector.com.

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January/February 2016

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Understanding the

Social Security Number ROUTING SLIP Initials

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In this issue we are going to take a close look at one of the major tools a tracer uses in his hunt, the social security number (SSN).

It is said that one of the ways the United States differs from many other countries is that we do not issue a national identifier number, but our social security number, supposedly unique to each of us, comes pretty close.

The use of the SSN has expanded significantly since its inception in 1936. It was originally created solely to keep track of the earnings history of workers for Social Security entitlement and benefit computation purposes. It has since come to be used as a nearly universal identifier. Currently the SSN is assigned at birth, and enables identification and tracking of individuals as well as locating assets and financial information.

In this article I will attempt to briefly explore the history and meaning of the SSN, as well as the Social Security Administration’s (SSA) master file, generally known as the Numerical Identification System or Numident. I will also attempt to trace the historical expansion of the uses of the SSN by professional tracers.

Today, use of the SSN has expanded substantially and may be the most commonly used numbering system in the United States. As of December 2008, the SSA had issued over 450 million original SSNs, and nearly every legal resident of the United States had one. The SSN’s very universality has led to its adoption throughout government and the private sector as a chief means of identifying and gathering information about an individual.

Creating the SSN scheme and assigning SSNs to U.S. workers was no easy task. Passage of the Social Security Act in August 1935 set in motion a huge effort to build the infrastructure needed to support a program affecting tens of millions of individuals.

A numbering scheme was seen as the practical tracking device and thus, the employer identification number (EIN) and the SSN were created. The current SSN is composed of three parts: ■■ The first three digits are the area number ■■ The next two digits are the group number ■■ The final four digits are the serial number

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Skip Tracing Advisor Ron Brown

The three-digit area number is assigned by geographic region. One or more area numbers were allocated to each state based on the anticipated number of SSN issuances in the state. Prior to 1972, the numbers were issued to local offices for assignment to individuals; it was thought this would capture information about the worker’s residence. Until 1972 the area number represented the state in which the card was issued.

■■ Generally, area numbers were assigned in ascending order beginning in the northeast and then moving westward. For the most part, people on the east coast have the lowest area numbers and those on the west coast have the highest area numbers.

■■ 586 was divided among American Samoa, Guam, the

Philippines, Americans employed abroad by American employers and, from 1975 to 1979, Indochinese refugees.

■■ 580 was assigned to Puerto Rico and the U.S. Virgin

Islands; sequences 581 through 584 and 596 through 599 were also assigned to Puerto Rico.

■■ Sequence 577 through 579 was assigned to the District of Columbia.

■■ Sequences 587 through 588 and 589 through 595 were assigned to Mississippi and Florida, respectively, for use after those states exhausted their initial area number allotments.

■■ Sequence 729 through 733 has been allocated to the

Department of Homeland Security (DHS) for SSNs issued through the Enumeration at Entry (EaE) program, described below.

■■ No SSNs with an area number in the 800s or 900s, or with a 000 area number, have been assigned.

Continued to page 13 January/February 2016

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News

Desk Bureau Development

CFPB Revises Appeals The CFPB’s supervisory appeals process was revised on November 3. This was the first revision to the process since the original was published in CFPB Bulletin 201207. Revisions to the appeals process includes limits on oral presentations to issues raised in written appeals and increases the expected time to issue a written decision on appeals from 45 to 60 days.

Of the numerous changes to the appeals process Alan S. Kaplinsky, partner and practice leader with the Consumer Financial Services Group at Ballard Spahr, LLP,

doubts direct affects to agencies. “Frankly I don’t view any of the changes having a material impact. Before you could not appeal a decision and now you cannot. The other changes are as ministerial, and not substantive. The take away from all of this is, if you have undergone an examination and you receive a Potential Action Alan S. Kaplinsky and Request for Response (PARR) letter, you need to focus on that letter and prepare the most persuasive response Continued on page 17

Brown - Continued from page 12 ■■ No SSNs with an area number of 666 have been or will be assigned.

In a July 3, 2007, Federal Register notice, the SSA solicited public comment on a proposal to change the way SSNs are assigned (SSA 2007b). Under this proposal, the SSA would randomly assign SSNs from the remaining pool of available numbers, and the first three digits would no longer have any geographic significance. The SSA contends that doing so would ensure a reliable supply of SSNs for years to come, and would also reduce opportunities for identity theft and SSN fraud and misuse.

By understanding the SSN concepts and intricacies the professional tracer can better use SSNs to their advantage.

In the next issue we will explore the details of the group and serial numbers. Until then, good luck and good hunting.

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

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January/February 2016

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Compliance Areas Debt Buyers Must Address

ROUTING SLIP Initials

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For years, debt buyers could operate outside the scope of compliance and regulation in the accounts receivable management industry. This was not because debt buyers were attempting to be deceitful, rather this sector of the industry was so new and innovative that too much was unknown to attempt to govern it.

Those days are over and no longer are debt buyers overlooked.

In fact, they are now very much on the radar of the CFPB. It was only a matter of time as compliance administration was on the rise with larger creditors and other first parties. The CFPB is already visiting the organizations. Most would agree that debt buyers are not far down the list.

What can debt buyers do to prepare themselves for a call from the CFPB? Debt buyer certification programs are fairly new in the industry and several options are available. The standards for most of these certification programs focus on the primary areas of concern debt buyers are facing these days. Topics including media, chain of title, agency management, and credit bureau reporting all make the cut. I would like to examine these four primary topic areas and present some solutions for capturing and maintaining the compliance related information using the same technology debt buyers are using to manage their inventory. Let’s set the precedence that present day debt buyers are managing their inventory with proper, enterprise level software.

Any debt purchasing operation still managing inventory using spreadsheets is destined for compliance violations and trouble with the CFPB should there be an audit.

Media

Also referred to as account and debtor documentation, media is crucial for debt buyers and it is important to have software that will allow for media attachments on a per account basis.

Often, media is not included in the actual purchase agreement.

It usually must be requested from a separate entity, or if the seller does have the media, it comes with an additional cost. In many systems, media attachment components are not included but hopefully your software allows for custom configuration and you are able to add media attachment options.

Make sure media attachments are available at both the ac-

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Date

Technology Advisor Sam Edens

count and consumer levels. For example, there may be a contract at the account level but separate credit reports if there is more than one responsible party on the account. The setup should be able to store the credit report for the respective responsible party. Most media is large in file size and because of this, disk space will be consumed quickly. Proper system sizing is often overlooked and needs to be planned accordingly. Lastly, in the event a consumer pursues litigation, the debt buyer will need to be in a position to confirm the consumer opened the account and is a responsible party by presenting media.

Chain of Title

The history of account ownership is referred to as chain of title.

When a debt buyer purchases an account from a creditor or another debt buyer, the ownership is transferred. Like media, chain of title is additional documentation for the account. It should be requested at the time of purchase and any information or media related to chain of title should be stored in the software at the account level. You will want to have this information for compliance purposes, in the event of litigation, or if you eventually sell the account. Storing the chain of title in your software will also position you to set up your placement strategies with external agencies and provide them with chain of title for each account in the placement file.

Agency Management

As a debt buyer, knowing the agencies you are placing with is almost as important as knowing your own agency. At least that is what an auditing entity will expect. Until sold and ownership changes hands, debt buyers are responsible for all their January/February 2016

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“You may be expected to know any certifications your agencies have achieved, how they enforce and maintain data security.”

Edens - Continued from page 14 accounts regardless if being worked inhouse or placed with an external agency.

There is some very nice software available for debt buyers that will not only allow for automated account placement strategies, but will also include features for ranking an agency, certifying an agency, and tracking compliance related data points for an agency. If you cannot find the latter in your current software, it is in your interest to build out the agency management module to capture compliance related information. For example, you may be expected to know any certifications your agencies have achieved, how they enforce and maintain data security related to your inventory, and their backup and restore procedures. In most cases, this is

not only a single field of data. You should be able to capture and store short text descriptions of the processes or attach documentation to the external agencies that are configured in your software.

Credit Bureau Reporting

How debt buyers report to the credit bureaus is one of the most common violations in the industry. Far too often, workflow elements for credit bureau reporting is not detailed enough. Ensure your credit bureau reporting workflow is not re-reporting debtors and is also deleting debtors from the bureau’s file upon resolution of the debt or in the case of bankruptcy. Be ready with documentation that details your process. It is much easier to hand an auditor a detailed docu-

ment and walk through it together than attempt to explain your process for others to appraise. Credit bureau reporting practices are also key processes debt buyers should understand about each of their external agencies.

Understanding and documenting compliance standards such as those described above will help prepare you for a visit from the CFPB. At the very least, you will have addressed and standardized some important, compliance related business processes should the CFPB never call or visit.

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.

Helping Debtors Find the Money

Continued from page 10 delinquencies, recent bankruptcies (seven years), open tax liens, chargeoffs, or non-medical collections accounts in the past 12 months.

■■ They can only have six or fewer credit inquiries on their credit report in the last six months.

■■ Must have at least two revolving

credit accounts currently open.

When customers apply, they are assigned a rating based on their score and credit that determines the risk to other investors. If accepted, the listing is published and investors can invest into this loan or several. Along the way they ask personal questions regarding the loan and why. They may use portions of credit reports available to them and some of the questions may be used to test a borrower’s integrity in answering them.

They may also ask for the customer’s tax returns or paystubs.

Although I don’t recommend it, in the new world of peer-to-peer lending it is even possible to become an investor/ lender and finance your favorite customer’s debt.

July/August 2015 www.CollectionAdvisor.com

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Determining Meaningful Involvement

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In being asked to determine if a particular movie was so obscene as to be to banned, Supreme Court Justice Potter Stewart famously wrote that while he could not intelligibly define obscenity, “I know it when I see it.” Fast forward 50 years, the collection industry finds itself on the wrong end of the same definitional conundrum.

In Bock v. Pressler & Pressler, the court concluded that Pressler violated the FDCPA for failing to be “meaningfully involved” in the process of filing collection lawsuits. The court explained, “whatever reasonable attorney review may be, a foursecond scan is not it.” Further, the court stated that a “rapid look-over of the complaint … cannot really be considered a careful review of the complaint, let alone an exercise of the professional skills of a lawyer.”

Further, the CFPB filed an amicus brief in Pressler and contended that the Court need not decide precisely what steps an attorney must take to ensure the representations he/she makes when filing a debt-collection complaint. Rather, the CFPB stated that the attorney must be meaningfully involved in the case and reach a professional judgment that filing of the lawsuit is warranted and not deceptive.

For attorneys practicing in the area of legal debt collections, we are all hoping for rules that we could easily follow. However, the reality of today’s situation is more like, “you’ll know it when you see it.”

What is Meaningful Attorney Involvement?

While the case law and recent litigation involving collection law firms provides few guidelines on an affirmative definition of meaningful involvement, we do know a number of things as of the drafting of this article. An attorney must be involved in the process in which a lawsuit is prepared and that a cursory (think four second) review of the matter is not good enough. The use of legal assistants and technology have been discussed by the court and CFPB; however, there have been no clear directions given.

In my opinion, a detailed process as to how the system of preparing and signing a lawsuit must be developed; and an attorney must be involved in the process.

Bright Spots and Bright Lines in the Consent Decrees

In September 2015, well-publicized consent decrees were issued involving major players in our industry. In the aftermath of these decrees, it became clear that major changes were on the way, impacting everyone from debt purchasers to original creditors to collection law firms. While different to some degree, both of the decrees are consistent on a number of topics. First, the CFPB

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ROUTING SLIP Initials

Date

Legal Collection Advisor Fred N. Blitt

had concerns that original creditors who sell debt do not warrant their balances and often provide little or no documentation, as well as making it difficult and expensive to receive documents after sale of the debt. Second, that to proceed to suit, plaintiffs and their attorneys must be able to substantiate the debt with original account level documentation, with the consumer’s name, last four digits of the account number, the balance and in certain circumstances, the terms and conditions applicable to the debt.

Third, it requires a full, authenticated chain of title. Fourth, either a document signed by the consumer opening the account or evidence of a purchase, payment or other use of the account.

These consent orders, while not defining “meaningful involvement” provide some insight as to what specifically the CFPB is looking for as part of the collection process. Further, while these consent orders only involve two large debt purchasers, everyone in the industry is looking to them for guidance.

These companies have a few months to change their processes to meet the terms of the consent orders. As such, collection law firms must address these changes within their own organizations.

A Way Forward

At the NARCA Fall conference in Washington, DC, NARCA’s immediate past president Joann Needleman helped organize meetings with the CFPB which were attended by Director Richard Cordray along with many of his staff. While it was clear from these meetings that the goal of the CFPB is to protect consumers, it was less clear that they understood debt collection lawyers agree with that goal. We must continue to educate on the importance that debt collection plays in our nation’s economy, keeping costs of lending lower, which benefits all consumers.

We look forward to receiving rules that are clear, easy to follow, and that are mindful of each state’s rules of ethics and respect the codes of civil procedure.

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. January/February 2016

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News

Desk

“The bottom line is the CFPB is inventing its own form of due process with no collection rules expected for 2016.”

Continued from page 13 you can to deter an enforcement action. Sometimes you can get the CFPB to back away or limit the enforcement action in some way.”

A PARR letter is used to notify a CFPB supervised entity, “the Bureau is considering taking supervisory action,” after an examination. A supervisory action includes a non-public memorandum of understanding or a public enforcement action based on the potential violations identified.

The CFPB expects examiners to share preliminary negative findings with the supervised entity throughout the examination. The company may respond with any relevant information to correct the findings. The PARR letter provides an opportunity to include “any reasons of fact, law or policy as to why the Bureau should not take action against the entity” along with supporting documentation. According to the revised appeals process, if the Bureau’s senior leadership on the Action Review Committee decides on a public enforcement action then the decision cannot be appealed.

CFPB Debt Collection Rules Update

The CFPB issued its eighth Semi-Annual Report to the President and Congress on November 24 covering April 1, 2015 through September 30, 2015. The report provides an update to the steps taken to develop proposed rules on debt collection. The CFPB first accepted comments on this Advance Notice of Proposed Rulemaking (ANPR) on debt collection in November 2013. Notably, the CFPB released its most recent regulatory agenda on the same day as the Semi-Annual Report where it stated it would extend debt collection pre-rule activities through February 2016.

This is particularly disheartening to the collection profession which has repeatedly asked for rules to follow.

The prior regulatory agenda published in May, 2015 predicted debt collection pre-rule activities would last through December, 2015.

“The schedule for the debt collection regs. has still

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has not convened a SBREFA panel, a panel of how it will affect small business,” Kaplinsky noted. “They may be realizing the full extent of the undertaking.” A SBREFA panel refers to the Small Business Regulatory Enforcement Fairness Act (SBREFA). The panel would review the proposals the CFPB is considering for regulating small business, which comes after the proposed rules are determined. The panel will meet with small entity representatives (SERs) to discuss the proposals and the issues it asks the SERs to provide input. Only then will the panel issue its report to the CFPB. If history repeats itself, the SBREFA panel members will be the CFPB, the Chief Counsel for Advocacy of the Small Business Administration (SBA), and the Office of Management and Budget’s Office of Information and Regulatory Affairs. The selected SERs may participate in the Panel outreach meeting in person or by teleconference, but generally travel and participate in the process at their own expense, according to the CFPB’s fact sheet on the SBREFA panel process.

While the exact number of representatives selected varies, typically 15 to 20 small business representatives are selected to meet with the panel. This may represent the best opportunity for collectors to present their case.

Richard Cordray appeared sympathetic to the small business burden at a CFPB event in Oklahoma City in early 2015. With collections being a bastion of small business entrepreneurs, it is possible the collection perspective will be incorporated in the final rules.

After the SBREFA panel meets, they will issue a report on the input received from the SERs within 60 days of convening. If the Bureau proposes a rule, any small businesses or organizations, including those that participated in the panel outreach meeting, may submit formal written comments during the public comment period.

The bottom line is the CFPB is inventing its own form of due process with no collection rules expected for 2016. “It suggests to me there will be no proposed debt collection regs until the second half of 2016, and actual rules in 2017,” said Kaplinsky. “Hopefully they are being thoughtful to produce a thorough set of rules.”

January/February 2016

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Agency Spotlight

Avoiding Bait ‘n’ Sue Blues

BY JOSHUA FLUEGEL

L

egal collection requires exacting tactics as this is the portion of the collection process where legal ambiguity must be wrestled into black and white. The odds of fair treatment for a collection professional are shifted even more out of proportion by the increased use of predatory attorneys using rehearsed consumers as bait. Collection Advisor shines the Agency Spot- Dennis J. Barton III light on The Barton Law Group and talks to its managing attorney Dennis J. Barton III about how to deal with these predatory attorneys, stay on the right side of the courtroom, and his affinity for strumming a good folk song.

Why did you become an attorney and what brought you to collections? When I was young, or even in college, I never had aspirations to be an attorney. My father owned a neighborhood lumber and hardware store, and I grew up wanting to get into business. He emphasized to me that I was always welcome to one day take over the family business, but he encouraged me to make sure I considered other options in life. As a junior at Indiana University, Delta Faucet hired me as a summer intern in the Human Resources Department. It had a progressive employment motivational philosophy rooted in positive reinforcement and personal fulfillment. I focused in human resources and graduated from I.U.’s Business School with a double major in business management and human resources management.

Straight out of school, I worked as a

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human resources representative at Arvin Meritor, the world’s leader in exhaust manufacturing. My office was in a three acre manufacturing plant where I was in charge of the hiring and discipline of hourly workers who were unionized by the United Brotherhood of Carpenters and Joiners. Fortunately, I spent most of my day negotiating employee discipline and company policies with the union officials that fought hard to protect their members.

Every time a complicated or impactful situation arose, I was required to contact the company’s attorney, and that attorney or outside counsel made the ultimate decisions. I started to understand the impact and influence lawyers have due to their superior knowledge of potential legal consequences of even well-intended actions.

I wanted to operate at that level. Soon thereafter, I took the LSAT and applied to Washington University School of Law.

In 2009, I had been a lawyer for six years working on a wide variety of cases, and I opened my own firm after locking down a commercial real estate developer as a commercial collections client. That business gave me enough income to buy the time I would need to build a respected firm. Less than three years later, Tim, a

special process server I had used a handful of times in the past approached me about taking over a collections law firm that was owned by a solo practitioner who suddenly died in an automobile accident. My firm was retained by his clients who were collection agencies and first-party creditors.

While I had some collection cases before, I was a general practitioner taking whatever cases came my way. With the new collection clients, the focus of my practice quickly became collections litigation.

While representing these firms as a collections attorney, I was also retained by them as their consumer law defense attorney, which now is about half of my practice.

Almost overnight I became a collections attorney and a consumer law litigator. I remember when Tim was trying to convince me to take over the collection clients he told me, “Collections is easy; it runs itself.” If only that was even half true.

What kinds of collection law does Barton Law Group practice and do you see any trends in the particular branches of collections? My collection cases mostly consist of medical debt, consumer loans, and commercial and residential real estate. A significant trend that affects me relates to medical debts.

Many predict such debt will not be reportable in the not too distant future or at least reported in a different way. That will drive down the common incentive to pay those bills to rehabilitate bad consumer credit ratings.

For those who might not know, why would they predict such a thing for medical debt? There’s been some discussion that medical debt differs from most other types of debt.

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“If people knew that if they paid it off it would be taken off the record entirely, that would actually encourage payment.”

These are not people who decided to make an investment in something that failed, tried to get a payday loan, or buy a sports car. These are people who had an unexpected event whether they became ill or injured. There is a philosophy that reporting medical debt is not a fair indication of that person’s creditworthiness.

They didn’t plan on these expenses.

The counter to that is no matter how you got into that position, you got into that position and it still affects your creditworthiness. There’s a movement toward the idea that once a debt is paid it is deleted from your credit report instead of it just showing as satisfied. I actually think that would help in the collections area. If people knew that if they paid it off it would be taken off the record entirely, that would actually encourage payment.

What was a particularly interesting case and what knowledge did you take away that you think is very important? Approximately two years ago, a consumer called the agency asking about a letter she received 25 days prior to the call. During the call, the collector offered a payment plan. I was retained to defend the agency after the consumer very soon thereafter filed suit alleging a violation of the FDCPA. She claimed that the offer of a payment plan overshadowed her 30-day dispute period.

The plaintiff argued that an unsophisticated consumer would not understand that she still had a full 30 days to dispute the debt even after being offered a payment plan.

Those facts are a common fact pattern and far from interesting. The interesting part is that when I deposed the plaintiff, I asked her where she was during the call and who was in the room with her during her call. I asked those questions because I suspected the call was a bait call.

She admitted that she was at her lawyer›s office when she called and that her lawyer was present. I filed a motion for summary

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judgment arguing that even if the collector overshadowed, that claim only occurs when the unsophisticated consumer standard applies. I further argued that such a standard cannot exist when the lawyer is in the room because the consumer is no longer unsophisticated.

like www.insideARM.com that have a free list serve that provides information on legal trends in the industry.

What are the most dangerous pitfalls in legal collections and how do you avoid them? Staying out of the courtroom starts with adopting

Meeting at The Barton Law Group

The case settled for other reasons, so I did not get to make this argument in front of a judge that I really respected.

What I learned, though, is to always pursue facts that support my suspicions. FDCPA cases are strict liability cases that are broadly construed in favor of the consumer. Collectors need to find any evidence to defeat liability, and this case reminded me that I need to dig deep into the facts to find potential defenses.

What do you think is the easiest thing a collection agency could do to stay out of the courtroom?

This industry is governed by the same federal statute, but it is interpreted differently by courts all around the country, sometimes unexpectedly with radical outcomes.

Staying current with the law is essential to knowing what new plaintiff’s theory is landing agencies in court. The easiest thing agencies can do is to make sure one or more people subscribe to organizations

policies and procedures that comply with the many consumer laws that regulate our industry (e.g., the Fair Debt Collection Practices Act (FDCPA), Fair Credit Reporting Act (FCRA), and the Telephone Consumer Protection Act (TCPA). In order to make those policies and procedures meaningful, they must be effectively communicated to new employees.

While it is true that all employees need continuing training on issues of compliance, not placing an emphasis on new employees is a common mistake. What is true in collections is true in most if not all other fields. Whether you are a collector, a welder on an exhaust systems assembly line, or a professional golfer, initial training can set the pace for the remainder of your career. It is far more efficient for agencies to invest time and money into teaching a new employee the correct way to do something rather than spend more time and money attempting to alter bad Continued on page 20 January/February 2016

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Agency Spotlight

“There are a few indicators of whether or not a bait call is going on. “ Continued from page 19 practices and techniques developed over weeks, months, or years due to inadequate training.

Emphasis of initial training is easier said than done when agencies have client demands that force new collectors to experience “on-the-job training” and “baptism by fire.” The temptation to cut corners in new employment orientation and training can be significant. Agencies create future pitfalls by setting up for failure those employees, their agencies, and ultimately their clients.

What do you think is a recent case that you feel could influence collections or affirm a direction the industry is headed? In any lawsuit, a plaintiff must have “standing” to bring the suit. It is a requirement under Article III of the U.S. Constitution. It means that a plaintiff must have an interest in the case because the plaintiff suffered actual harm.

In Spokeo, Inc. v. Robins, a consumer filed a class action lawsuit on a technical violation of the FCRA. The district court ruled he did not. The Ninth Circuit Court of Appeals overturned the district court and held that the FCRA’s statutory rights established an injury sufficient to satisfy standing. This April, the United States Supreme Court agreed to hear the case, and on November 2, 2015, the Court heard oral argument. If the Supreme Court rules that a technical violation is insufficient to have standing in a FCRA case, it may open the flood gates as to other statutory claims that affect this industry such as the FDCPA, TCPA, and others.

What is something every collection manager should be doing to help enforce compliance?

Monitoring employees is an important step in the enforcement of compliance.

This can come in the form of listening to a random sample set of recorded calls or monitoring live calls. The goal is to identify problems before they become

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problems. This will enable collection managers to identify improper policies and procedures or collectors not following them before a consumer files a compliant with a state agency, the CFPB, or a plaintiff’s attorney.

affect my credit?” and no matter what the answer is they just move on to the next question, there is something amiss about that. People don’t just ask questions and move on if they are truly interested in the answer.

What is a specific or common infraction to listen for? In my geography bait calling is big.

There are a few indicators of whether or not a bait call is going on. One of those indicators is that it sounds like it is on a

What is your greatest achievement thus far in your career? My greatest achievement as a lawyer has been taking over the cases of the attorney that passed away, hiring his employees, and picking up the pieces of his ongoing cases all the while teaching myself collections law. Many of the procedures of that lawyer’s firm (and thus many of the practices of his employees that I hired) were not in compliance with the FDCPA and/or state regulations.

Fortunately, those employees taught me much of the nuts and bolts of the practice, and we worked together to bring the firm into compliance. My success was due to hard work by me and a team of people that I grew to trust and heavily rely upon.

Barton rockin’ out.

speakerphone. The consumer will make a phone call from their own phone using speakerphone and plaintiff attorney is sitting right next to them with plaintiff attorney’s phone recording the conversation. That way when they look at the phone records it will look like you were talking just to the consumer when in fact you were talking to the consumer and the consumer’s attorney.

One thing that collection managers can do is make sure collectors are aware of that. Once they have identified there is a possibility that it is a bait call they need to be trained on how to handle it. Either disconnect the call altogether, turn it over to a manager or someone who is especially good at dunning.

Another indicator is that the person asks the question and almost no matter what the collector says the person just moves on to the next question. That’s not natural. If someone says, “Will this

What do you like to do in your free time? I am the proud father of two daughters, ages three years and six months, respectively.

That means I have very little “free” time.

In those rare occasions when I can slip away, I enjoy playing guitar. My mother gave me my first guitar when I was twelve, and I have played off and on ever since.

Tell me about your experience with music. My mom was a big guitar player. She played in church and a folk music group. She always liked it. She was always encouraging of me being in folk music. It was not only fun but it was good for intellectual development. It exercised both sides of the brain, the analytic and the creative. She was always encouraging of that.

I was never in a group. I was always solo. I mostly played folk and rock; mostly influences from Bob Dylan and the like. When I was in college I cut a CD and had a lot of fun with it.

January/February 2016

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talking like

movie heroEs

BY JOSHUA FLUEGEL

I

nspiration is a tool more valuable than collection software. It can take a routine workday and turn it into the beginning of an agency-changing movement. The right inspiration can spur a collection professional to pursue a new market, generate new solutions to remedy an agency-specific problem, or adopt a personal philosophy that may very well shape the environment of an entire collection floor. All a person has to do is find this match to light the fuse. But where can a person find such a source? Of all the things a do-it-yourselfer can do, generate inspiration is not one of them. There is no map that reveals the crossroad of serendipity, applicability, and realization.

The only way I happen upon inspiration is to immerse myself in, well, stuff. Books, the outdoors, interaction with others, music, building projects, teaching, movies, all examples of ways to lead someone’s mind down an unexplored path.

One source of inspiration can be found on the silver screen in the form of the 1962 epic “Lawrence of Arabia.” For those who have not yet had the pleasure of experiencing this level of cinematic mastery, it is based on the story of real-life British soldier T. E. Lawrence and his exploits helping the Arabs in their revolt against the Turks.

There is one scene where Lawrence (Peter O’Toole) is trying to persuade a proud leader and beneficiary of the Turks’ residence, Auda ibu Tayi (Anthony Quinn),

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to join the Arab cause. When Lawrence questions the independence of Audi’s tribe due to payments from the Turks for Audi’s loyalty, Audi delivers these powerful words: “I carry 23 great wounds, all got in battle. 75 men have I killed with my own hands in battle. I scatter, I burn my enemy’s tents. I take away the flocks and herds. The Turks pay me a golden treasure yet I am poor, because I am a river to my people.”

This line says multiple things: 1) I am good at what I do and this skill gives me power. While counting wounds and kills may not be an ideal metric for the workplace, the point is made nonetheless. 2) I realize my responsibility and will use my power for mutual success. Employees want to know the leader of a company is invested in their professional well-being.

These ideas turn someone who is obeyed, into someone who is followed.

Communicating with employees about what has been done in the company and how it will lead to improvements that benefit everyone can be a simple yet powerful gesture that can reduce turnover and increase adherence to procedure.

A person can find a boss at any job.

Leaders can only be found at certain jobs and are usually sought out by the best.

Another movie that can inspire is the 1976 revisionist western “The Outlaw Josey Wales.” As it seems to be the

requirement in all westerns that there be an exchange between the title character and a Comanche chief, this one is no exception. What sets this particular conversation apart is its simplicity, eloquence, and sincerity. Sparing you multiple lines of dialogue, the scene comes down to Wales (Clint Eastwood) stating his party and the Comanche would inhabit the same area and would prefer to do so peacefully. This is stated plainly with conviction and little subjectivity. Impressed

by Wales’ message and presentation, the Comanche chief states, “There is iron in your words of life.” I agree.

Cinephiles interpret many things from this scene, which is significant considering its brevity. What strikes me is its lack of frills. Speaking plainly and sincerely presents a higher level of solidarity.

Not to say this should lead to a “my way or the highway” mentality but in a time of Twitter hashtags, buzzwords, and doublespeak, it can be reassuring to employees and colleagues to have iron in your words.

Plainly spoken directions, intensions, and feelings free of ambiguity and distrust can create environments, both personally and professionally, to which many might want to contribute. Perhaps you will be surprised by a person’s response to this technique as was Wales.

Implying a desire for mutual success and speaking directly are some of the many things inspired by great movies.

Let me know what movies inspire you at josh@collectionadvisor.com.

January/February 2016

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The Life of a Legal Collection Solution

BY JOSHUA FLUEGEL

Like all things, a collection agency’s use of a legal collection solution has a cycle.

The agency examines their particular requirements, finds software to suit those requirements, and then proceeds to acquire the ideal software and implements it accordingly. What follows are years of integration, use, and then the possible eventuality that the agency moves to different software for various reasons. Ironically, the biggest things an agency must address in this process are answering the hundreds of small questions.

Considerations for an agency when first buying legal collection software are pivotal and must be answered carefully.

“Understand yourself and your company,” said Ranjan Dharmaraja, CEO of Quantrax Corporation. “Software does not solve problems, people do. Understand the people you have. Make Ranjan Dharmaraja sure you have a team that can handle today’s complex environment, before considering any changes!”

Carl A. Briganti, president and founder of Collection Solutions Software has noted a trend in collection professionals shopping for legal collection software and placing importance on automation.

“One other thing we have really seen in the past eight to 10 months is what we like to call hard controls,” said Briganti. “That means that many organizations, especially in Carl A. Briganti the legal collections process, want to rely more on an automated process, rather checks and balances, that deliver a hard control rather than training.”

When selecting the correct software solution for your agency, reviewing it

22

function by function can be time consuming but well worth the effort. The selection criteria for functionality like document management must be clearly defined.

“There are many moving parts here as there are different systems in the marketplace,” said Fred Blitt, managing partner at Blitt and Gaines. “Due diligence is key.

First define what your goal for the tracking system is, then look at vendors in the marketplace. I would go visit a site that uses the system and see it work in real time.”

An effective collection solution will be limited if it is not well integrated into the company. One possible way to ensure integration is to custom build the solution according to the company’s needs.

“If you are investing in a new, flexible system, start from scratch, and draw your collection process on paper, paying no attention to your new software,” said Dharmaraja. “Assuming your software can adapt to your business (as opposed to you having to adapt to your collection software), you should then be able to ‘map’ your processes into the new system. Unfortunately, this is easier said than done.”

Once the legal collection software has been implemented, enacting secure processes to ensure compliance is a linchpin process that must be done effectively.

“One of the pivotal mistakes most organizations make is not identifying the responsible party the moment in time that legal action is created and recorded,” said Briganti. “During the process of a legal action you’re going to have to know first if that legal case party is responsible.

You will also need to know if that legal case party qualifies to be sued for that specific legal action that’s tied to that debt.

That debt has a slew of compliance applied to it.

In addition, security must be maintained through proper document management. No more than authorized per-

sonnel should have access. This includes both external and internal stakeholders.

“If external, there needs to be layers of security in place for someone to have access to the system,” said Blitt. “Likely the system will be on a separate network that houses the documents. Internally, there needs to be software that tracks the access to documents and what users can do with it. For example, can agents print or just view?”

When the indications for a change are present, they can be numerous but subtle. A fair amount of objectivity would be beneficial.

“When the risk and the cost of doing business are not as balanced, you may want to consider moving on to a new platform,” said Briganti. “In my eyes, compliance and liability really are the key factors. If you do not have the controls in place, not training, but literally controls to invoke compliance as a hard line and as a training method, then that’s a good time to consider switching to so me scalable technology that very easily allows an organization to implement live controls from the back end.”

Above all, communication with key agency stakeholders such as collection managers and business developers along with advice from your vendor will lead to indicators of an ideal legal collection solution for the agency.

LEGAL COLLECTION Software PRODUCTS Ajility CSS IMPACT! CollectOne eCollections RMEx January/February 2016

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MORE ONLINE

Legal Collection Software Checklist

CHECKLISTS & TRAINING TOOLS

he following is a checklist collection professionals can use to help objectively determine which legal debt collection solution to select. Agency decision makers (evaluators) rank each one of the listed features on a scale from 1 to 5 in their respective column based on the feature’s importance to the agency (1 being least important and 5 being essential). Then in the “Software Possesses Functionality” column, decision makers can check off whether or not each feature is possessed by various prospective collection solutions. The final section on this checklist is composed of features suggested by collection software vendors for consideration.

T

Legal Collections Functionality

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ty t es ali c n s u s o od se ti Pr Pos unc F

BUDGET: ________________ DATE OF RE-EVALUATION: _________ Decision Makers: ____________________________________

Integrated with pre-legal collections Integrated with Microsoft Word Track multiple cases for each account Multiple, configurable lines of legal business History of legal actions Held billings Release/approve billings for invoicing View legal documents history Unlimited number of liable and non-liable parties Individual case party statuses Track party garnishments Track party services Track party judgments Case and case party tasks scheduled automatically Multiple check requests based on court requirements

Recovery Functionality

Multiple legal documents based on court requirements Pre charge-off collections Post charge-off recovery Agency/attorney management Asset sales Automated file processing

Functionality

Pre Charge-Off Collections

Repossession tracking Disputes/deduction codes can be assigned Identifies and tracks problem invoices Coded problems separates from other receivables Offers customer and invoice-level notes

Vendor Recommended Functionality

Electronically reproduces/transmits invoices

23

Import demographic changes via spreadsheet

Contributed by: Hubbard Systems

Import financial transactions via spreadsheet

Contributed by: Hubbard Systems

Re-classify costs as recoverable/non-recoverable

Contributed by: Hubbard Systems

Reimburse clients for non-recoverable costs not collected from consumers

Contributed by: Hubbard Systems

January/February 2016

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2016 Collection Resource Directory

Analytics & Data CallMiner Eureka / myEureka / EurekaLive callminer.com maureen.szlemp@callminer.com 781-547-5666 CallMiner Eureka is an enterprise interaction analytics solution that automates the process of analyzing every interaction in the customer journey across all communication channels.

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

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

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.

ECONOMIC STIMULUS

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.

FOR YOUR BUSINESS

Comtech Systems Collect!

Credit and Debt Collection Software Lyons Commercial Data collect.org Financial Institution On-Demand Verification Our &economy and our industry are undergoing unprecedented info@collect.org 800-661-6722 change. It has never been more important that we understand Collect! combines ease of use with total integration Attorney Referral Service and efficiently operate our businesses. of functions. Accounts are efficiently tracked from almost 40 years our innovations have been a partner No receive obligation efficiency analysisis concluded the time•you them until activity The National ListForof Attorneys in our client’s success. We’re committed to providing Credit for your existing software and they•are closed.

Collect! keeps track of critical Attorney Referral Service fresh ideas and developing creative solutions. As part information automatically.

Total integration provides • Free data conversion of that commitment we’ve developed the CollectOne for seamless and accurate month end invoices and • Feature rich collection software Stimulus Plan, a cost-effective opportunity to help you Collection Software statements with full account histories.

• Deferred payment options ensure that your business is best managing change.

Affirmative Technologies NSF Item Processing | Software affirmativeusa.com 888-216-1808 | Web Portal

• No interest financing options

DAKCS Software

• Free third-party interfaces Systems and our Stimulus Plan offer at • Free CollectOne Web Portal Beyond.Net www.collectone.com/stimulus • Free CollectOne legal software or call us at 888.816.3333. dakcs.com • Commitment to client care sales@dakcs.com | Beam Software Dialer • Improved bottom line Change is here. Profit from it.

800-873-2527 Collection & Portfolio Management Software DAKCS Software Systems has been an industry leader for over thirty years. Headquartered in Ogden, Utah, CDS Software DAKCS provides a one stop shopping solution for a CollectOne Minimize costs. Maximize results.diverse client base. DAKCS is committed to providing collectone.com their customer community with all the tools they need info@collectone.com to succeed in the ever changing A CDS Software Solution 888-816-3333 ARM business, today and in the future.

CollectOne is an award winning suite of debt collection solutions that provides a feature-rich set of Pamar System automated business processes designed to minimize Pamar Collection System costs and maximize results.

Learn more about CollectOne

Sentinel Development Solutions, Inc. eCollections ecollections.com sales@ecollections.com 515-564-0585 eCollections is the most modern and flexible collection management system available with unequaled enterprise features and capabilities including powerful automation and built-in payment portals.

Simone Systems Software, LLC Ultimate Collection Control

Compliance LexisNexis® Risk Solutions LexisNexis ® Accurint ® for Collections lexisnexis.com/risk/receivables-management 866-528-0780 LexisNexis collections solutions assist debt recovery professionals with increasing workflow efficiencies, greater insight into debt portfolios, collecting more in less time and achieving greater profitability.

Collection Support Services Applied Innovation Inc

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

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

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

RZ Designs Collections Management

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January/February 2016

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2016 Collection Resource Directory

Cornerstone Support State Licensing and E&O Insurance cornerstonesupport.com info@cornerstonesupport.com 888-445-8660 Cornerstone Support is the premier licensing and insurance provider to the collection industry; professionally trained to assist you with all of your state licensing needs.

High-End Collection Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

Mail Services

PCI Group Letter Services pcigroup.com choosepci@pcigroup.com 803-578-7700 PCI Group provides outbound letter services via mail or email and online payment processing to the CSS IMPACT! HD™ 2.0 (Enterprise), the industry’s leading ARM | Collections & Compliance Platform delivering decades collection industry. By developing leading-edge Our economy and industry are technologies we ensure fast, secure and costour effective of deep rooted industry acumen for the ARM, Collections & change.

It has never been more im document delivery.

Compliance sectors.

IXP (Lite) also available.

Our economy and our industry are undergoing unprecedented Garnet Capital and efficiently operate our busine Debt Brokerage for charged-off account change. It has never been more important that we understand RevSpring IVR and efficiently operate our businesses.

For almost 40 years our innovations have been a partner Receivables, in our client’s success. We’re committed to providing Electronic Payments Communications

For almost 40 years our innovations have been a partner • No obligation efficiency analysis Collection Solutions fresh ideas and developing creative solutions. As part & Payments in our client’s success. We’re committed to providing • Credit of forthat your existing software commitment we’ve developed the CollectOne Software, Inc. Advanced Payment fresh ideas and developing creative solutions. As part revspringinc.com Stimulus Plan, a cost-effective opportunity to help you • Free data conversion CSS IMPACT! HD™of2.0 Systems that commitment we’ve developed the CollectOne248-567-7300

ensure that your business is best managing change. cssimpact.com • Feature rich collection software Stimulus Plan, a cost-effective opportunity to help you Credit Card & Check RevSpring’s communication and online payment carlb@cssimpact.com • Deferred payment options ensure that your business is best managing change.technology Processing Merchant Services tools include secure document Learn morecreation, about CollectOne 818-593-4830 | Software No interest financing options apsofga.com analytics,•text messaging, mobile, andourmore. and Stimulus Plan offer at CSS IMPACT! HD™ 2.0 (Enterprise), the industry’s leading Learn more about CollectOne Free third-party interfaces jennifer@apsofga.com RevSpring• maintains rigorous compliance programs www.collectone.com/stimulus | Software Platform delivering decades | Web Portal ARM | Collections & Compliance and our Stimulus Plan offer at 800-482-4561 • Free CollectOne Web Portal or call us at 888.816.3333. and security certifications. of deep rooted industry acumen for the ARM, Collections & www.collectone.com/stimulus APS provides a full range of electronic payment | • Free CollectOne Portal | Dialer legal software or call us at 888.816.3333.

Compliance sectors. IXPWeb (Lite) also available.

Change is here. Profit from it. solutions, including credit, debit & HSA cards, check, • Commitment to client careSoftware Medical Collection | Dialer and ACH transactions, along with multiple software • Improved bottom line Change is here. Profit from it. integration options, web payment portals, and the Legal Software CDS Software IKEY Product Suite with the attorney endorsed Reg E CollectOne compliance solution.

CDS Software Minimize costs. Maximize results. collectone.com CollectOne info@collectone.com Minimize costs. Maximize results.

Collection Solutions collectone.com A CDS Software Solution 888-816-3333 Software, Inc. info@collectone.com CollectOne is an award winning suite of debt A CDS Software Solution CSS IMPACT! HD™ 2.0 888-816-3333 collection solutions that provides a feature-rich cssimpact.com CollectOne is an award winning suite of debt collection set of automated business processes designed to carlb@cssimpact.com solutions that provides a feature-rich set of automated minimize costs and maximize results.

818-593-4830 business processes designed to minimize costs and CSS IMPACT! HD™ 2.0 (Enterprise), the industry’s leading maximize results.

Collection Solutions ARM | Collections & Compliance Platform delivering decades of deep rooted industry acumen for the ARM, Collections & Compliance sectors. IXP (Lite) also available.

Payment Vision Payment Gateway PCI Group Letter Services pcigroup.com choosepci@pcigroup.com 803-578-7700 PCI Group provides outbound letter services via mail or email and online payment processing to the collection industry. By developing leading-edge technologies we ensure fast, secure and cost effective document delivery.

25

ECONOMIC S ECONOMIC STIMULUS FOR Y

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

FOR YOUR BUSINESS

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. .

Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

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

Continued on page 26 January/February 2016

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change. It has never been more important that we understand and efficiently operate our businesses.

For almost 40 years our innovations have been a partner in our client’s success. We’re committed to providing

• No obligation efficiency analysis

‘

2016 Collection Resource Directory • Credit for your existing software

fresh ideas and developing creative solutions. As part

• Free data conversion

of that commitment we’ve developed the CollectOne

• Feature rich collection software

Stimulus Plan, a cost-effective opportunity to help you

• Deferred payment options

ensure that your business is best managing change.

• No interest financing options

| Software

Continued from page | Web25 Portal | Dialer

Learn more about CollectOne

• Free third-party interfaces

and our Stimulus Plan offer at www.collectone.com/stimulus or call us at 888.816.3333.

• Free CollectOne Web Portal • Free CollectOne legal software • Commitment to client care

Change is here. Profit from it.

Mid-Range Collection Software

Skip Tracing

• Improved bottom line

LexisNexis® Risk CDS Software Solutions CollectOne Minimize costs. Maximize results.

LexisNexis ® collectone.com Accurint ® for Collections info@collectone.com A CDS Software Solution lexisnexis.com/risk/receivables-management 888-816-3333 CollectOne is an award winning suite of debt collection 866-528-0780 solutions that provides a feature-rich set of automated LexisNexis collections solutions assist debt recovery professionals with increasing workflow efficiencies, business processes designed to minimize costs and greater insight into debt portfolios, collecting more in maximize results. less time and achieving greater profitability.

Collection Solutions LocateSmarter Software, Inc. Batch & Online CSS IMPACT! HD™ 2.0 Skip Tracing Platform cssimpact.com locatesmarter.com carlb@cssimpact.com info@locatesmarter.com 818-593-4830 888-254-5501 CSS IMPACT! HD™ 2.0 (Enterprise), the industry’s leading LocateSmarter is data provider focused on innovation ARM | Collections & Compliance Platform delivering decades and data quality. LocateSmarter offers skiptracing of deep rooted industry acumen for the ARM, Collections & products such as phone append, bankruptcy, deceased, Compliance sectors. IXP (Lite) also available. cell phone scrubs and more.

Predictive Dialers

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

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

Noble Systems Corporation Noble Enterprise Suite noblesystems.com info@noblesystems.com 404-851-1331 Noble Systems Corporation is a global leader in the customer communications industry, providing innovative solutions for Unified Communications, Business Process Management and Analytics.

MicroBilt MicroBilt Collections Suite microbilt.com 800-884-4397 MicroBilt is the leading data provider for collections, skip tracing and provides multiple alternative and collections-specific credit reports, as well as bank account data.

PDJ Services Covert Record Retrieval pdjservices.com contact@pdjservices.com 800-298-1153 We specialize in Telephone, Cellular, Nationwide Bank & Verified Current Employment Locates. When you want 100% verified accurate information for unlisted & cellular phones, people locates, bank & employment locates...you’ll call us!!

Search Net Management Asset Searches

Continued on page 28

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January/February 2016

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ADVANCED PAYMENT SYSTEMS INTRODUCES IKEY CERTIFIED SOLUTION SUITE Web based payment platform Reg E Compliance Solution with embedded eSignatures Debtor initiated payments Collector assisted authorizations Multi-path contact management Determines & tracks eligibility for each form of contact - Text, email, cell phone

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and efficiently operate our businesses.

For almost 40 years our innovations have been a partner in our client’s success. We’re committed to providing

‘

2016 Collection Resource Directory

fresh ideas and developing creative solutions. As part of that commitment we’ve developed the CollectOne Stimulus Plan, a cost-effective opportunity to help you

ensure that your business is best managing change.

| Software

Continued from page 26

| Web Portal

TransUnion TLOxp and Collection Solutions transunion.com/industry/collections 800-856-5599 TransUnion supports customers in achieving their goal of collecting more while spending less. From prioritizing accounts, improving skip tracing or streamlining workflow, TransUnion can help.

U.S. Tracers Proprietary Place of Employment ustracers.com 800-360-5601 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.

Place of employment verification

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Small Office Collection Software

CDS Software CollectOne Minimize costs. Maximize results. collectone.com info@collectone.com A CDS Software Solution 888-816-3333 CollectOne is an award winning suite of debt collection solutions that provides a feature-rich set of automated business processes designed to minimize costs and maximize results.

Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

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

Virtual Collections Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com carlb@cssimpact.com 818-593-4830

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

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LEARN MORE

© 2015 TransUnion Risk and Alternative Data Solutions, Inc. All Rights Reserved.

and our Stimulus Plan offer at

Voice Broadcasting

TLOxp® from TransUnion quickly pieces together the most concrete facts about individuals and businesses.

TLOxp.com/collections or call 800-856-5599

| Dialer

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Superior

RPC

solutions

The TLOxp solution is not provided by a "consumer reporting agency" and does not constitute a "consumer report," as these terms are defined by the Fair Credit Reporting Act, 15 U.S.C. Section 1681 et seq. ("FCRA"). The TLOxp solution may not be used in whole or in part as a factor in establishing an individual’s creditworthiness or eligibility for credit or insurance, or employment, nor for any other purpose under the FCRA.

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.

• No obligation efficiency analysis • Credit for your existing software • Free data conversion • Feature rich collection software • Deferred payment options • No interest financing options • Free third-party interfaces • Free CollectOne Web Portal

January/February 2016 • Free CollectOne legal software Volume 16, No. • Commitment to client care1 • Improved bottom line

Editor T. Steel Rose, CPA, ACG editor@collectionadvisor.com Managing Editor Joshua Fluegel josh@collectionadvisor.com Copy Editor Myrna Nelson Advisory Board/Columnists Fred N. Blitt Ron Brown Debra Ciskey Sam Edens Nick Jarman Harry A. Strausser III Publisher Angie Rose angie@collectionadvisor.com Advertising Brandon Bates brandon@collectionadvisor.com Production Andrea Bergeron Paul andrea@collectionadvisor.com Subscription Changes Joshua Fluegel josh@collectionadvisor.com The opinions given by contributing authors are their own and not necessarily the opinion of our staff and ownership. All trademarks used are the property of their respective owner.

Collection Advisor (ISSN# 1556-0813) is produced six times a year by Abide Media, P.O. Box 92342, Southlake, TX 76092, 888-610-1144.

Standard Mail postage paid at Sussex, WI 53089. ©2016 All Rights Reserved Magazine Publishing Group, Inc. Printed in the U.S.A.

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