January/February Issue

USING TECHNOLOGY TO EMPOWER COLLECTIONS

MAKING COMPLIANCE A VALUE-ADDED COMPONENT LONELY AT THE TOP? BEARING THE WEIGHT OF LEADERSHIP HOW SPEECH ANALYTICS CHANGED THE WAY WE DO BUSINESS WHY YOU ARE THE GOLDEN BULLET FOR SKIP TRACING RATCHETING UP YOUR COMPLIANCE MANAGEMENT SYSTEM LARGE EQUIFAX SECURITY HACK PRIVATE DEBT COLLECTION PROCEDURES BLOCKCHAIN: WHAT YOU NEED TO KNOW IRS COLLECTIONS NEW DEBT BUYER LICENSE REQUIRED TECHNOLOGY IS THE DEBT COLLECTION HERO TAKE CONTROL OF YOUR DIGITAL REPUTATION Vol. 18, No. 1

Kavitha Subramanian

January/February 2018

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COMPLAINT RESOLUTION AND REPUTATION MANAGEMENT ISSUE

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Sam Eidson

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Fred N. Blitt

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Ron Brown

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Nick Jarman

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Harry A. Strausser III

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Debra J. Ciskey

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T. Steel Rose

THIS ISSUE MADE POSSIBLE BY: CDS Software.............................. Inside Front Cover Melissa Data..............................................Back Cover IDI, Inc................................................................... Page 3 CSS IMPACT........................................................ Page 5 VeriFacts.............................................................. Page 7 DAKCS................................................................... Page 9 Cornerstone Support.................................. Page 11 Sentinel Development Solutions Inc....Page 28 Simplicity Collection Software ............Page 28 Collect!................................................................Page 28

e m o c l e W H

appy New Year! 2018 is already off to an eventful start. At the time this issue of Collection Advisor is being printed, CFPB Acting Director Mick Mulvaney is promising big changes to the bureau. He has expressed the importance of allowing capitalism to thrive and reeling in the seemingly unlimited power of the CFPB. In his acknowledgment of the importance of paying bills, he gives credence to the idea that collection professionals are not just debt collectors; they are Accounts Receivable Professionals who work with consumers to optimize their financial standing with creditors. As A/R Professionals wait for CFPB reform, special attention can be paid to improving complaint resolution and reputation management. Collection Advisor dedicates this issue to such an endeavor with columns to help you improve your standing with consumers and clients.

In keeping with this issue’s theme, Collection Industry Advisor Nick Jarman talks about your company’s digital reputation and how you can make it work for you. Compliance Advisor Debra J. Ciskey looks at recent material from the CFPB and shows how it can help you ratchet up your compliance management system. Benchmark Advisor Harry A. Strausser III discusses bearing the weight of leadership through delegation, strategic decision making and effective complaint management. Agency Advisor Sam Eidson details how speech analytics reduced complaints and changed his agency for the better.

Also in this issue is Legal Collection Advisor Fred N. Blitt revealing how compliance can be used to sell your services as a value added attribute. Skip Tracing Advisor Ron Brown explains why you are the magic bullet for skip tracing.

Next issue, Collection Advisor releases its ever-popular skip tracing issue covering the latest tactics for locating the elusive consumer. In keeping with the theme, we will also take a look at today’s skip tracing software.

Until next time, we look forward to hearing from you.

Joshua F luegel

Editor-in-Chief

josh@collectionadvisor.com

Quantrax...........................................................Page 29

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January/February 2018

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CollectionAdvisor.com ACCESS ONLINE

USING TECHNOLOGY TO EMPOWER COLLECTIONS

January/February 2018

Volume 18, No. 1

ADVISORS 4

AGENCY ADVISOR

How Speech Analytics Changed the Way We Do Business Sam Eidson 6

LEGAL COLLECTION ADVISOR Making Compliance a Value-Added Component Fred N. Blitt

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Buyers Guide

FEATURES

28

21

Mulvaney Disturbed by His Power as CFPB Acting Director

What You Need to Know About

Blockchain

12

IRS Collections New Debt Buyer License Required

BENCHMARK ADVISOR

Lonely at the Top? Bearing the Weight of Leadership Harry A. Strausser III

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THE BOTTOM LINE Video Services

Private Debt Collection Procedures

Take Control of Your Digital Reputation Nick Jarman

Technology is the Debt Collection Hero T. Steel Rose

CATHERINE M. BRENNAN, MEGHAN MUSSELMAN AND KAVITHA SUBRAMANIAN

COLLECTION INDUSTRY ADVISOR

FINANCIAL TECHNOLOGY ADVISOR

The CFPB’s New Payday Rule

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10

18

JOSHUA FLUEGEL

SKIP TRACING ADVISOR

COMPLIANCE ADVISOR

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Why You are the Golden Bullet for Skip Tracing Ron Brown

Ratcheting Up your Compliance Management System Debra J. Ciskey

T. STEEL ROSE AND JOSHUA FLUEGEL

Complaint Resolution and Reputation Management Game

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14

9 16

Large Equifax Security Hack

16 19

T. STEEL ROSE AND JOSHUA FLUEGEL

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What Are You Missing

from Your Legal Collection Software?

Comparison Chart

JOSHUA FLUEGEL

DEPARTMENTS

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Welcome

Collection Industry Top Product Nominees January/February 2018

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How Speech Analytics Changed the Way We Do Business

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Shortly after the Dodd-Frank Act and CFPB were created our organization made the decision to stay ahead of regulation by tying a collector scorecard to our collector bonus program. The purpose of the scorecard was to incentivize professional and compliant collections while driving performance. Our proprietary scorecard used randomly selected call recordings in the evaluation process. The scorecard consisted of five calls per agent that were a minimum of four minutes long and the consumer had to be willing, unwilling, able or unable to pay. Bankruptcies and disputes were not scored. The four categories we evaluated were opening of the phone call, call progression, obtaining full and complete information and compliance with all debt collection laws as well as our employee code of conduct. The scorecard used a proprietary formula to assign an overall scored percentage encompassing all of the aforementioned subjects. The overall scored percentage on the scorecard would be the percentage of the bonus dollar amount the collector received for that month.

For example: if the collectors’ performance earned a $1,000 bonus but they received an 80% on their scorecard they would only earn an $800 bonus check. As I’m sure you could imagine, some collectors did not adapt well to this change. The perception was that the company was trying to take money from them.

We experienced some negativity and even lost a few collectors who couldn’t accept this change. Almost eight years later we’re confident we made the right decision to hold collectors accountable for how they collect the debt.

In early 2015 we decided to add speech analytics to our way of doing business. In the beginning we underutilized the product with the basic reports provided. During the fourth quarter of 2016 we were contemplating whether speech analytics was worth the cost. We knew that the product had all of the bells and whistles but if we weren’t taking advantage of them, why continue paying the cost? The only way we could justify keeping speech analytics is if it could replace a full-time employee in our compliance department.

We spoke with our speech analytics vendor, expressed our concerns and advised them that the only way we would continue to use their product was if we could create an automated scorecard that replaced our manual process. They agreed to come onsite and help us build the scorecard we have today. There are nine compliance elements of the scorecard including proper ID of self, consumer, company and client, mini-miranda, two-party consent, FDCPA violations, risk and abusive language and legal action mentions. Now, instead of only scoring five calls per agent we evaluate their full body of work throughout the month.

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We spent the next two months testing the scorecard for accuracy. We wanted to ensure that we felt comfortable with the scorecard prior to rolling it out to our collectors and ultimately affecting their income opportunity. Senior management feared rolling this out to our collectors because of how it was received years ago. In order to avoid negativity and turnover we had to explain how the automated scorecard not only benefits our organization but also how it benefited the collectors. Believe it or not, we didn’t have to sell the idea to the collectors because the majority of their scores actually increased. It all makes sense because if the collector failed one call out of five that accounted for 20% of their overall score. With the new automated scorecard one failed call out of two hundred has a much smaller impact on their overall score. We have also created standalone categories for excessive silence, profanity, TCPA risk and after-call work which monitors how long it takes for the agent to go from one call to the next. These reports are sent out to the compliance department daily. If there are any issues the collector is addressed immediately. Within three months of implementing the automated scorecard we were able to reduce our compliance department by one full-time employee.

Now that we’ve successfully completed our compliance scorecard using speech analytics, our focus will shift to collector efficiency. A few of the categories we will add are demanding the balance, offering settlements, payment arrangements, call duration and a seasonal category for tax time talk-offs. Even though speech analytics can be costly and may not be a fit for all organizations, there are ways to offset the cost by incorporating efficiency into your business objectives.

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

January/February 2018

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Making Compliance a Value-Added Component

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I have been faulted for being too optimistic or seeing positives in what appear to be negative outcomes. Perhaps that stems from my being a lifelong Cubs fan, alive for almost half of their 108 year World Series drought, but, whatever the reasoning, it is hard-wired into my nature. With that preface, I am here to tell you something that appears counter-intuitive and wildly optimistic: Your compliance department can be a value-added component of your collection law practice.

Let that sink in a moment before I explain because I can tell you, if you don’t see it that way, you aren’t alone. In fact, I had the same view until our compliance management processes evolved over the past few years. Simply put, compliance is what you make of it – it can be a burden or you can use it as a tool to increase your firm’s performance. I can’t guarantee you will look forward to client audits but I can say that if you use it as a tool to pro-actively analyze your practices, policies, procedures and your staff, it can translate into increased revenue.

It is easy to consider your compliance team compensation as simply non-revenue production expenses. Frankly, those team members don’t produce revenue. Compared to employees who prepare complaints, attorneys who appear in court or collectors calling on accounts, the answer is easy. However, when you think about the positive impact your compliance management staff can have on your firm, you can see some real benefit. This article will discuss some of the benefits we see at my firm.

Human Resources Having a tight compliance management

system helps your human resources department. I’m sure many of you have had this experience: new employee starts, begins training day one, leaves badge on desk and walks off the job never to be seen again. Obviously, it’s not ideal but it happens occasionally. Although the new hire is told all about the training and testing required, when they experience it first hand, it can be quite daunting. This highly regulated environment we all live in is not for everyone. Frankly, it weeds people out early and that’s a good thing compared to coaching up a new hire for three months only for them to leave for another job. This new normal sets the tone in our office. Following the rules and regulations are just what we do. It applies to people in the mailroom all the way up to my office as managing partner. No one is singled out and it helps our managers.

Audit and Reporting Our internal audit areas and control reporting teams help meet client audit expectations and increase our performance. Internal audit personnel will determine if staff

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Legal Collection Advisor Fred N. Blitt

is properly following policies and procedures. In instances where there are defects, training will take place to help the staff understand the issues and fix them. This process will increase staff productivity. Control reporting takes on a similar role and provides my firm with the opportunity to find potential errors before they become an audit finding. A good example is making sure scrubs are done on accounts prior to demands being sent. Daily control reporting provides this data.

Compliance Management System Having a solid compli-

ance management system can separate your firm from others in the industry. Every one of our larger clients has a robust audit program. Some clients visit our offices as much as quarterly.

Meeting and exceeding client expectations can have a major impact on your client relationships. Clients want to work with the top firms and help create new opportunities for them.

Focus on Compliance Finally, our increased focus on compli-

ance has led us to identify trends in lawsuits, threatened lawsuits and regulatory actions. Because we are tracking these, in detail, by client, by firm and by cause of action, we identify issues in our own processes, issues that may never show up on a client audit that you can address with changes in practices and policies to save yourself exposure, legal fees and consumer damages.

As a result of these and other changes brought to life by compliance, we have changed our mindset on compliance and audits – we now use them as challenge, as a benchmark and as a marketing opportunity for the firm. Your professionalism, the ability to have a staff dedicated to compliance and audits demonstrates you value the client, you have the staff to handle the client’s demands and ensure your key staff on legal and the collection side can dedicate their attention to the practice of law.

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 2018

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TriVium

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CALL RECORDING

Why You are the Golden Bullet for Skip Tracing

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I concluded the last article with the statement, “the bottom line is, always has been and always will be, the knowledge and skills of the professional tracer who has the natural ability to disseminate the data, separate what is good and bad and then solve the puzzle by putting the right pieces in the right spots.” That statement is the key that unlocks the door which leads to the pathway which draws you one step closer to the golden bullet each professional tracer seeks.

It is my opinion that the elusive golden bullet, which enables Ron Brown and empowers a tracer to find missing people and things, comes from within and must be cultivated by the tracer if they desire success in this very exciting and challenging profession. must develop a very broad vision path rather than a narrow path, It has been alluded to that today’s professional tracers are noth- which would limit their ability to see the outliers. It is often the ing more than modern day bounty hunters who seek out people and outliers, the small bits of information, seemingly unimportant or things for payment. With certain reservations I would have to agree unrelated, which will provide the vital clues that ensure success with that assessment of our profession. But in today’s environment when spread, analyzed and then rejoined. of cyber tracking, social media and The professional tracer is alaccess to huge data mining sources ways on the alert for repetition when “The elusive golden bullet must be containing consumer information, viewing the outliers. A few examples it requires so much more to be sucwould be a person being hunted may cultivated by the tracer if they desire cessful than just access to the inforfrequently use another name. The success in this very exciting mation. A professional tracer must tracer should research the name and possess the skills required to massage see where it comes from and why and challenging profession.” and manipulate the data to produce that particular name is used. It may the desired results. be the tracer learns the person being This article is dedicated to assisting a tracer develop a stan- hunted has a particular hobby or frequents a specific restaurant. dardized procedure to extract the specific data required to locate a The outliers must be viewed as parts of a puzzle, separately they person or thing and may be considered a blueprint for establishing may have little meaning or relevance, but when joined together your own golden bullet. they may provide the clues required to locate the person or thing Let us begin by understanding the statement “natural abil- being hunted. ity to disseminate the data.” The first part, “natural ability,” is a The next part of the statement is also critical to the tracer’s characteristic which all people possess in their DNA but do not success, “separate what is good and bad.” There is a lot of good develop to the extent needed to become a true hunter of people or information available from both free data sites and pay data sites things. All people are born with a hunter instinct. A baby hunts on the net. But the tracer must accept and come to terms with for the bottle, as we grow older we hunt for knowledge. A trip to just because information is on the Internet or from a confidential the grocery store or automobile dealership is basically a hunt. The informant, relative or employer, does not necessarily verify that hunter instinct will show up in many places, how and what we it is good and valid data. The net contains so much information enjoy for recreation, the sports we enjoy and in the profession, we that is false and misleading a tracer must always be alert to the fact choose. The true hunter loves the chase of the hunt as it appeals to that anyone can put anything on the net at anytime to mislead the basic desire to win. Number one is for the tracer to understand and in many cases misdirect the tracer. I would encourage all of that they possess this genetic trait passed down from their ances- those who aspire to be true professional tracers to verify, verify and tors and find ways to further unleash and develop the skill sets re-verify all data obtained from all sources. required to be a true hunter.

Now to the final part of this missive, “the knowledge and Now let’s look at the second part of that statement, “dissemi- skills.” The professional tracer must never think they have reached nate the data.” Disseminate is defined as a verb meaning to scatter a point where there is nothing left to learn. Knowledge is the power Continued on page 11 or spread. This ability is very important for a tracer because they

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Skip Tracing Advisor

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Large Equifax Security Hack

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he largest ever breach of sensitive information occurred by way of Equifax on July 29 of last year. The leak may have affected 143 million people, or as many as 50% of Americans. In response, Equifax is selling their TrustID service to consumers. Signing up for the service also acts as an agreement to not participate in a lawsuit.

With cyberattacks becoming more common, all companies’ cybersecurity risk programs could benefit from an independent validation from a CPA. This June the AICPA released a new cybersecurity risk program examination, as part of its redefined SOC reports. SOC previously stood for Service Organization Controls; now the term stands for System and Organization Controls. SOC for cybersecurity has been added to the SOC 1, SOC 2, and SOC 3 reports.

The new SOC for cybersecurity examination offers a structured approach to implementing security controls to protect information and systems from compromise and to detect and recover from security events that are not prevented.

While the SOC 2 report is a general use report for service organizations that provides services to other organizations, the cybersecurity examination is not limited. It is also broader,

BY T. STEEL ROSE AND JOSHUA FLUEGEL

allowing no carve out. Organizations are responsible for all controls within the risk management program regardless of who is responsible for performing the controls.

The cybersecurity risk management engagement does not include details on the operating effectiveness of controls over a period of time.

The SOC 2 report includes the following components: a description of the cybersecurity risk management program created by the organization and presented to the auditor, a management assertion letter vouching for the description of the program, and an audit opinion on the organization’s cybersecurity program from the auditor.

Bloomberg reported executives sold stock in the company before going public with the leak on September 7. The transactions in question were initiated by Chief Financial Officer and Corporate VP John Gamble, who sold $946,374 worth of shares; President of U.S. Information Solutions Joseph Loughran, who sold $584,099; and President of Workforce Solutions Rodolfo Ploder, who sold $250,458 in shares. As Bloomberg notes, these transactions were not pre-scheduled trades and they took place on August 2, three days after the company learned of the hack.

One vendor. All the solutions.

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January/February 2018

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Take Control of Your Digital Reputation

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Reputation is defined as the general estimation in which a person or company is held by the public. A keyword in that definition is estimation, which can then be defined as an opinion or a judgment. Your reputation is simply what others think and say about you. It is the foundation and cornerstone that will determine the success or failure for your organization. While your reputation can be completely established for a long period of time, it can very suddenly change causing significant impact on your company.

As the Internet continues to be the central resource where individuals go to discover information about companies or services, how you manage your digital reputation is vital. There are numerous aspects and websites on the Internet that impact your digital reputation and some of them are:

Search Engines Consumers and clients alike want to know what

company they are dealing with and the quickest way to find this information out is to search the company’s name by using a search engine. The three largest search engines: Google, Bing, and Yahoo! determine based on their web page rankings which web pages and information are displayed and in what order. The objective is to have as many positive or informational web pages populate the results at the top, while any negative information is pushed to secondary search result pages. There are numerous SEO (Search Engine Optimization) companies out there and for good reason, to enable your company to maintain a positive digital reputation.

Better Business Bureau The BBB is a nonprofit organization fo-

cused on advancing trust in corporations by collecting and providing free business reliability reviews. When a complaint is filed against your company it becomes attached to your permanent online file with the BBB. The unfortunate part here is whether your company committed any wrongdoing or not; the information is publicized for all to see on their website which ranks very high in all search engines. While the BBB gives you an opportunity to respond to each complaint and posts your response online, it doesn’t absolve your company of having to continually deal with the permanent mark on your digital reputation.

Message Boards Message boards or Internet forums are online

discussion sites where consumers can post messages and hold conversations. For those who have been in the debt collection industry long enough, you are probably aware of the numerous message boards that publicize unfavorable comments and posts about creditors, agencies, and collectors alike. Some of these message boards are frequented so much by consumers they tend to rank very high in search engine rankings. Over the years, message boards relating to caller IDs have become increasingly popular with the purpose

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Collection Industry Advisor Nick Jarman

being to report who is calling from what phone numbers and discuss details of the call. While some of these message boards post legitimate complaints about services, there are many out there that have unreliable and inaccurate information that can deal a substantial blow to your digital reputation.

Consumer Protection Financial Bureau The Consumer Financial

Protection Bureau has indicated its intention of making complaints it receives from consumers against the collection industry public. Consumers simply go to their website and submit the complaint which is reviewed by the CFPB and then a response from the company is requested. From there the consumer reviews the company response and the CFPB reviews and may investigate further. At the end of the process the case may be posted to their consumer complaint database. While this is all relatively new, it is yet to be determined if professional discretion will be involved as to whether or not the complaint goes online for all to see even when there has been no wrongdoing. It will be important for you to monitor the complaint database as government domains seem to have a high search engine ranking.

Now that there is a better understanding of what impacts your company’s online presence, let’s discuss some options available for you to move your digital reputation in the right direction.

Press Releases There are several industry websites that offer free or

pay-for-service press releases that are displayed on their websites and distributed by email. While those types of press releases are useful, using a commercial press release distribution company such as Business Wire or Marketwired is the route to go to really make an impact on the Internet. These companies have several distribution options from a local, regional and national level and they are priced accordingly. These press releases push your press release out to hundreds and potentially thousands of news outlets and websites that start to create backlinks and begin to fill up search results when your company name is searched. In addition, the press releases create additional marketing opportunity from the news outlets to which it gets distributed.

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“Control negative or false information.”

Social Media Another option available to promote a positive digi-

tal reputation is through social media. Facebook, LinkedIn, Twitter and Google Plus are the main players in this arena. Take the time to create a page on each for your company and start to get the word out on the happenings within your organization. Utilize these websites as a way to share positive information about your company such as promotions, accomplishments, and philanthropy. There are also websites such as www.ifttt.com which allow you to set up triggers for all of your social media websites.

For example, if you update your Facebook page it automatically triggers an update of a dozen or more specified social media accounts your company has to save you time from having to update them individually.

Search Engine Optimization The best and most advanced op-

tion in creating a positive digital reputation is to invest in a professionally designed website with developers that utilize the latest in SEO methodology. Search Engine Optimization is the process of affecting the visibility of a web page in search engines natural search results. The trick is to fill in as many backlinks throughout your website in order to point search engines to specific pages within your company website. The more frequently a web page appears in search engine results, Brown - Continued from page 8 that they possess which sets the professional apart from the amateur, that power which allows them to enjoy success where others have failed in their tracing endeavors.

Knowledge is an accumulative factor and the professional must constantly be aware of changes and improvements related to the tracing industry as well as consumer protection statutes. Skills are the tracers tools in trade and the skills required to locate people and things must constantly be used, sharpened and upgraded where required.

There are many skill sets a tracer must possess: massaging and manipulating data, persuading informants to provide information and the use of neuro linguistics to extract information from reluctant sources.

The professional tracer, through their knowledge and skills, can become their own “Golden Bullet” and they then will be the key to success.

Until next time… 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. .com

January/February 2018

the more visitors to that web page which is a major factor in determining its ranking in search results.

Google Alerts Google Alerts is a service offered by Google which

automatically notifies users when a set of pre-defined search terms are matched from any website. Companies can enter their company name along with any search keywords that may be associated with their company for when someone uses a search engine. The notifications are sent only when a match is found and is generally sent

by Google through email. Google Alerts is a good way to monitor information about your company when it arises on the Internet.

Managing your digital reputation can be boiled down to two important elements, controlling what individuals see and say about you online. If you are able to utilize the options outlined in this article it will allow you to manage your digital reputation and help control any damages caused by negative or false information posted online about your company. Take the necessary measures to positively and aggressively manage your digital reputation, because if you don’t do it, someone else will define it for you.

Nick Jarman is the Senior Vice President of Diversified Consultants, Inc. Jarman served the last three years on the Board of Directors for ACA International and is the past President of the Missouri Collectors Association.

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Lonely at the Top? Bearing the Weight of Leadership ROUTING SLIP

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There is a popular best-selling book, “Don’t Sweat the Small Stuff… and it’s all Small Stuff” by Richard Carlson. It is an appropriate sentiment expressed in this title for those that lead or manage others. If you are the boss, you are afforded freedoms and relaxed expectations over others. This is particularly true if you are an owner of your organization. Those in upper management often lament that their time is consumed by trivial issues, baby-sitting employees, putting out fires and ultimately dealing with compliance issues and frustrations. This small stuff is overwhelming and takes over our lives.

Everyone, by human nature, tends to gravitate to tasks and activities with which we are comfortable. This comfort zone can be like a drug. We continually want more of it because it is familiar, easy for us and often brings us enjoyment. Often these comfortable spots represent jobs that others could or should do thus allowing us to focus on the bigger, more significant issues in our organization. Carlson says, “You are what you practice most.” Instead of the manager or CEO we become the bookkeeper, the skip tracer, the client service representative, the counselor or the janitor!

As the boss, the top gun, the big cheese, it is commendable to be flexible. There is value in knowing a little about a lot having the ability to step in where necessary. As President of my agency, for years I had developed the title of “handy man.”

Anything that went wrong in the building came to my desk.

Leaky toilets, plugged toilets, florescent bulbs that blew out, ice on the front sidewalk, a file cabinet drawer that was stuck and a furnace that wouldn’t ignite. I handled it promptly, and actually enjoyed that dynamic… well, not the blocked toilets. If we allow ourselves we can get caught in a deep hole of comfort that becomes larger and larger the longer we immerse ourselves in it.

There is a popular old adage that says, “It’s lonely at the top.” We often feel the weight of the world, or at least our company, perpetually on our shoulders. What we need to do is plot out our firm’s next move. What is the most important significant change to orchestrate? What direction should we head?

What is critical to the very survival of our organization? Are my biggest clients happy? Profitable? A fear emerges that, “we don’t know what we don’t know.” How do you acquire the knowledge you need to make the right decisions? When will I know that the decision I made was right? There can be lots of sleepless nights… even if you aren’t in Seattle.

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Benchmark Advisor Harry A. Strausser III

Here are some ideas that might help put you in the right direction:

It Doesn’t Have to be Lonely at the Top

Good leaders surround themselves with a supportive and knowledgeable management team. Often these team members know much more about certain topics than the CEO. Hire smart people that might even be smarter than you.

Develop a Repertoire of Outside Subject Matter Experts It is almost always true that someone has the answer to your question or problem. Start developing a robust list of people you meet, consultants, speakers, smart people you encounter and reach out to them when you have an issue. Often, connected people may not readily have your answer but they know where to go to get it.

Assess Often and Make Decisions Strategically

The world around us in the collections industry is changing rapidly. What was best or recommended yesterday may be the new taboo today. We must continually review our processes and be sure that we actually do what we profess we do. Engage in strategic thinking and planning with your team so you can easily and nimbly determine the best avenue for where your company is today.

Resolve Complaints and Maintain Your Reputation At

the very core of leadership in the accounts receivable management industry is the mandate that we maintain a highly responsive and sensitive culture surrounding consumer complaints. Every organization will encounter unhappy consumers. Timely and Continued on page 22 January/February 2018

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Ratcheting Up your Compliance Management System ROUTING SLIP

L

Initials

Date

Looking back over the year, it seems that 2017 was a tough one, fraught with natural and man-made disasters at many different levels. I know a lot of people who would like to forget about 2017 and move on to 2018, but then again, at this time last year, people were done with 2016 and ready for 2017 to come.

It is probably a good thing we don’t have the power to see into the future. This way, we can look optimistically to the new year, make our resolutions and hope for the best.

Debra J. Ciskey In the financial services industry we also experienced some disasters, including a major bank caught “selling” new accounts and other products to customers who didn’t buy them, like? Do you provide audio examples of someone doing it and a huge data breach at one of the largest and oldest credit correctly in various scenarios (inbound call, outbound call, call reporting companies. These occurrences still seem unfathomable to a workplace, call in which the other party won’t cooperate considering that by most accounts, they were preventable. with proper identification, for example).

How? By enforcing stronger The second bullet point internal accountability through above may take readers aback the implementation of and by the somewhat. This point underlines “Export your complaints book conformance with a detailed the CFPB’s expectations that, into a spreadsheet compliance management system. while compliance bulletins A compliance playbook, of sorts. are not law or rules adopted or other tool Let’s look at the Consumer through the normal Federal and look at your complaints Financial Protection Bureau’s rulemaking process, compliance comments on compliance with the bulletins is expected and the way the CFPB does. “ management system deficiencies required. The bulletins address in 2017. misrepresentation of the effect In the Summer, 2017 issue of Supervisory Highlights (Issue of paying a past due debt on a consumer’s credit score, and 16), the Bureau noted one or more debt collectors subjected misrepresentations regarding payment methods, including those to examination demonstrated the following deficiencies in that require the consumer to pay a processing fee. The bulletins, their CMS: referred to by the CFPB as Official Guidance, are here: https:// • Failure to identify the correct party as a result of inadequate www.consumerfinance.gov/policy-compliance/guidance/ policies and procedures, and training. implementation-guidance/ • Failure to update training materials with CFPB provided The third bullet point is another basic of compliance — direction in bulletins resulting in misrepresentations. avoiding calls at inconvenient times. There are two classes of • Failure to audit systems for compliance which resulted in inconvenient times: those defined by law and those defined communication with consumers at inconvenient times. by the consumer. We likely have our account management system programmed to alert collectors when the inconvenient The first item on the list above is a basic and key skill. times defined by law would apply to any account they may What consumer harm results from not identifying the correct access. Have we taken the further step to prevent calls to party? In many cases, third party disclosure can result. The consumers at inconvenient times defined by the consumer?

CFPB contends that inadequate policies and procedures, and After all, the Fair Debt Collection Practices Act gives inadequate training was the root of the problem. Training is consumers this right. Once we think we have accomplished a key component of a compliance management system. What the step, how has it been audited? Are collectors heeding the does your training around that basic first step in the collection warnings? Do we have other systematic controls in place to call, identifying the consumer, look like? What does it sound Continued on page 22

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Compliance Advisor

January/February 2018

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We conduct investigations of indirect disputes (disputes received via credit reporting agencies).

methodology.

We invest in our website by having it professionally designed to utilize the latest in search engine optimization

We fill our website with information about our company to improve our ranking with search engines.

Move Back 2 Spaces

Complaints filed by consumers with the CFPB are not validated in any way by the bureau.

We examine our CFPB complaints in search for spikes related to times of the year and client portfolios.

experienced novice, helpful helpfultips tipson onhow howtotomaintain maintain good experienced and and novice, good standing with regulators regulatorsand andconsumers consumerswhile whilelisting listing common standing with common missteps that should shouldbe beavoided. avoided. missteps that

agencyor orlaw lawfirm’s firm’slist listof ofpriorities. priorities.The TheComplaint ComplaintResolution Resolutionand andReputation Reputation agency Management Accounts receivable Receivableprofessionals, Professionals, Management Game Game provides provides accounts

The collection collectionindustry industryisisunder underconstant constantscrutiny. scrutiny.Therefore Thereforethe theresolution resolution The of complaints complaintsand andmanagement managementofofone’s one’sreputation reputationmust must near the top of bebe near the top ofof anan

Move Back 2 Spaces

tracks collector performance factors such as ID of self, minimiranda, twoparty consent, FDCPA violations and abusive language.

we utilize a scorecard that

To continually reduce complaints,

Move Back 2 Spaces

We do not check our listing with the BBB for complaints so we may respond to them and, in turn, improve our reputation.

Complaint Resolution and Reputation Management Game

We share positive information about us through social media like Facebook, LinkedIn and Twitter to promote our accomplishments and philanthropy.

We publish press releases with commercial press release distribution company such as Business Wire or Marketwired to make our name more easily found by search engines and improve our reputation.

Move Back 2 Spaces

We do not respond to complaints fully and in a timely way.

Our policies and procedures promote reasonable investigations of disputes according to the Data Furnishers Rule.

Google Alerts can be used to monitor information about your company when it arises on the Internet.

the way the CFPB does.

We regularly export our complaints into a spreadsheet or other tool and study them

We provide proper notice to consumers of a determination that a dispute was frivolous or irrelevant in accordance with the Data Furnisher Rule.

Well Done

We keep our own data on complaints we receive to analyze and determine if changes need to be made.

with the Data Furnishers Rule, we complete direct dispute investigations within the time periods required under FCRA.

In accordance

Move Ahead 1 Space

We patrol message boards to debunk inaccurate complaints and address legitimate ones.

Move Back 2 Spaces

We do not have enough staff to handle all inbound calls during busy times, thus causing complaints.

Start

The CFPB’s automated capability monitors the volume of consumer complaints for all companies named by consumers in complaint submissions.

short, medium, and long-term changes in complaint volumes in daily, weekly and quarterly windows.

The CFPB’s complaint monitoring algorithms identify

Technology is the Debt Collection Hero

I

In an economy where one in three Americans have a debt in collection, it is essential to collect debt to avoid passing the losses on to paying customers. While debt collection is essential for financial responsibility, the trick is to collect debt without alienating the customer, reduce complaints and avoid lawsuits. I say reduce complaints because they are inherent.

Debt collection is an area for constant complaints and has been, long before the CFPB permitted the posting of every complaint, legitimate or not. (The CFPB handled over 1.08 million consumer complaints by January 1, 2017.) Whenever I say I am editor for a magazine about debt collection technology and receive a negative response, I realize I am talking with one of the 35% of people who got behind on a debt and received a communication from a collection expert. Right away, we are on the defensive. We want to protect our honor, to say we are financially responsible. At the same time, who wants to pay a debt not owed? I know I don’t, but I have. I know people who pay the IRS just to stop fighting them and get back to work.

A scrutiny of debt collection complaints explains this notso complicated predicament. The complaints fall into four major categories: debt already paid, debt not owed, debt amount not verified and the wrong amount collected as debt. In many cases the financial professionals in banking created the problem and the financial professional in receivables catches the complaint. Data coordination is needed to enable debt collected by agencies to have a first-hand account of the facts. Companies contracting agencies need seamless technology to ensure accurate facts are passed on.

Technology becomes the hero in debt collection again. Data coordination is necessary between big data analytics, predictive analytics, process automation, mobile technology and social media.

Big Data analytics segregates data to answer key questions about

a consumer: What is her intent to pay? What is her ability to pay?

What will change her ability to pay and over what period? What is the likelihood of the change? Demographic data combined with the time of the day a consumer will respond to a call increase rightparty-contacts and talk-offs for debt collection agencies, the group we refer to as accounts receivable financial professionals (ARFP).

Big data opens up possibilities like speech analytics on every debt collection call. Advanced language-recognition programs track keywords during phone conversations and identify emotions of debtors and collection agents. If emotions rise and cursing begins, prompts steer conversations back on track. Supervisors see color-coded boxes on call-center computer monitors. A box turns red and expands when a call contains expletives. If there are long silences a supervisor can take over the call or whisper in the agent’s side of the call.

Small green boxes represent routine conversations when agents are reciting mandatory “mini-Miranda” statements. Ideally the program guides the agent to express appropriate empathy and

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ROUTING SLIP Initials

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Financial Technology Advisor T. Steel Rose, Editor

then provides phrases to produce payments. The end result is a score to rank ARFPs (top collectors).

Predictive Analytics uses data mining, machine learning, artificial

intelligence and statistical modeling to predict future events to gain reported increases of 50% in three months.

Process Automation

in debt collection replaces manual tasks with an automated process or a self-service portal. Efficiencies are gained by automating skip tracing, payment follow up and lining up the right phone numbers at the right time of day for a call.

Decision Automation

is gaining strides by teaching a machine to think, plan and act like an agent. While data science builds models based on past history of debt collection automated agents learn how to interact, follow up and close pending collections with debtors. Using email, SMS and chat the channels provide private, one-on-one discretion.

The ubiquitous mobile phone permits debt collectors to reach debtors wherever they are while technology determines which calls are permission based and not on the Do Not Dial list. Mobile phone payment apps surpassed other forms of payment this past Black Friday.

Social Media

is used to trace and prioritize customers for collection through their Facebook and Twitter accounts. While a debt collector must have considerable empathy and persuasive skills, technology can make the process faster and more accurate. Systems that cut down human intervention in the process these are merely tools at the financial professional’s disposal. The “art” of debt collection comes into play when these tools are utilized in concert to achieve the ultimate result, account paid.

A compliant call resulting in account paid or a payment plan puts the consumer on the road to restore financial responsibility and credit worthiness needed to make the next significant purchase of goods or services.

January/February 2018

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THE CFPB’S NEW PAYDAY RULE

BY CATHERINE M. BRENNAN, MEGHAN MUSSELMAN AND KAVITHA SUBRAMANIAN

I

n October, the Consumer Financial Protection Bureau issued its much-anticipated final Payday Rule. The Payday Rule, designed by the CFPB to end socalled “payday debt traps,” can be broadly divided into two sets of requirements: 1. Lenders must make an ability to repay determination and comply with related credit reporting obligations before making certain covered loans; and 2. Lenders must comply with limitations and disclosure requirements in connection with processing payments on covered loans.

The final Payday Rule regulates three different types of “Covered Loans”: 1. Short-Term Loans: closed- or openend loans where the consumer is required to pay within 45 days;

2.

Longer-Term

Balloon

Loans:

closed- or open-end loans where the consumer has longer than 45 days to pay, and either the loan must be repaid in a single payment, or has a “balloon payment” (e.g. at least one payment owed is more than twice as large as any other payment); and

3.

Covered

Longer-Term

Loans:

closed or open-end loans longer than 45 days, where the APR during any term of the loan exceeds 36% (as defined by Regulation Z) and the creditor obtains a “leveraged payment mechanism.”

“Leveraged payment mechanism” is defined as the right to initiate a payment transfer, through any means, from a consumer’s account, either on a single occasion or on a recurring basis.

This could include checks that are not deposited immediately by the lender or an electronic fund transfer authorization for a future date.

The ability to repay requirements and related credit reporting obligations apply only to the first two types of Covered Loans – short-term loans and longer-term balloon loans. The payment requirements apply to all three types of Covered Loans – short-term loans, .com

January/February 2018

longer-term balloon loans, and covered longer-term loans.

The Rule requires any lender making a short-term loan or a longer-term balloon loan to first determine that the consumer has the ability to repay the loan, while still meeting their basic living expenses during the term of the loan. A lender making these types of loans must also comply with a number of special credit reporting requirements. As compared to the proposal, the final Rule provides more flexibility regarding the income and debt verification requirements by allowing the lender to rely on written statements from the borrower.

The limitations on processing payments apply to all three types of covered loans: short-term loans, longer-term balloon loans, and longer-term covered loans. In connection with these loans, a lender is prohibited from attempting to withdraw a payment from consumer’s account after two consecutive failed payments, unless the consumer provides a new payment authorization. The lender may, however, initiate a payment transfer to collect a late fee or returned check fee without obtaining a new authorization.

The rule also prescribes model disclosures for lenders prior to making payment transfer attempts.

Lenders making covered loans must comply with the rule’s 36-month record retention requirement, and develop robust compliance policies and procedures related to their covered lending activity.

There are a number of exemptions from the rule, including purchase money loans, real-estate secured loans, credit cards, student loans, pawn loans, overdraft, wage advance programs and no cost advances. The rule also exempts (1) “alternative loans,” which are closed-end loans of $200 – $1,000, paid off in one to six months in two or more fully amortizing, equal payments, are exempt if the lender follows the rates and fees permitted under the National Credit Union Administration

Payday Alternative Loan Program (e.g.

28% interest and a $20 application fee); (2) “principal payoff loans,” which are short-term fully amortizing loans of $500 or less, with the option of up to two loan renewals, so long as the borrower does not have a recent short-term or balloonpayment loan; and (3) “accommodation loans” where a lender makes fewer than 2,500 covered loans per year, where the income from the loans does not exceed 10% of its gross profits.

The Final Rule was published in the Federal Register on November 17. Accordingly, the compliance deadline for the provisions of the final rule concerning the ability to repay analysis and limitations on payment attempts is August 19, 2019. In case it may be helpful, the final publication in the Federal Register can be found at www.federalregister. gov/d/2017-21808/page-54472.

Catherine M. Brennan and Meghan Musselman are partners in the Hanover, Maryland office of Hudson Cook, and Kavitha Subramanian is an associate in the firm’s Washington, D.C. office.

Ms. Brennan assists banks, investment banks and other licensed lenders in the development and maintenance of nationwide consumer and commercial lending proCatherine M. Brennan grams. She can be reached at cbrennan@hudco.com.

Ms. Musselman advises banks and other similar creditors in the development and maintenance of consumer credit programs, compliance management systems, and vendor management programs. She can Meghan Musselman be reached at mmusselman@ hudco.com.

Ms. Subramanian advises financial services clients on federal and state regulatory compliance matters. She can be reached ksubramanian@ Kavitha Subramanian hudco.com.

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Private Debt Collection Procedures

T

Weekly news video at CollectionAdvisor.com

Mulvaney Disturbed

by His Power as CFPB Acting Director T

he position of director of the CFPB seems to be settled, at least for the time being. A federal judge has refused to block the President Trump-appointment of Mick Mulvaney as acting director of the CFPB. The CFPB’s website acknowledges Mulvaney as the acting director while the Cordray-appointed Leandra English currently holds the title of deputy director.

After Cordray recently resigned as director of the CFPB, a struggle for the vacancy erupted between English and Mulvaney. English filed suit against the Trump administration citing the 2010 Dodd-Frank Act lays out a succession plan for the director authorizing the deputy director to hold the position until a White House nominee is confirmed by the Senate.

It has been suggested Cordray is likely poising himself to run for Governor of Ohio.

Mulvaney and the Trump administration have been vocal about their objection to the CFPB’s lack of accountability. At a press conference after his first day in the position, Mulvaney commented, “I’m just learning about the powers that I have as acting director. They would frighten most of you.”

“If you’ve really studied the constitutional nature of our government, if you’ve studied the way bureaucracy is supposed to work, it would both frighten and disturb you that this agency is as independent as it is,” Mulvaney added. “And it doesn’t surprise me, by the way, to the extent we are having a succession challenge as lodged by Ms. English. It isn’t surprising that that grows out of an agency that thinks it’s not accountable to anybody in the first place.”

- Video on CollectionAdvisor.com

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he IRS is owed $138 billion and private collection agencies, or PCAs, are now actively trying to collect some of it. As a part of the Fixing America’s Surface Transportation Act of 2015, or FAST Act, it is hoped $2.4 billion owed to the IRS can be collected over the next 10 years.

140,000 accounts with balances of up to $50,000 have been placed with four private firms: CBE, ConServe, Performant and Pioneer. These PCAs receive the taxpayer’s mailing address, a phone number and the balance due.

They receive no other confidential financial data.

These firms earn up to 25% of their receipts. They are governed by the Fair Debt Collection Practices Act which spells out when they can call, whom they can call, and what they can and cannot say. They will not use robocalls to contact taxpayers. All phone calls are recorded and PCAs undergo quality and customer satisfaction reviews.

These companies must clearly identify themselves as working for the IRS in all communications. When the IRS issues collection Notice CP40, it identifies the PCA and provides a unique authentication code. The PCA sends a separate letter to the taxpayer confirming the assignment and code. When the PCA calls, the taxpayer provides the code’s first five digits and the PCA confirms the last five digits.

The collectors ask the taxpayer to pay the IRS in full or enter into an installment agreement of up to five years.

If the taxpayer can’t do either, the PCA refers the account back to the IRS. A PCA will instruct a taxpayer to send a check made out to the U.S. Treasury directly to the IRS. A PCA has no authority to negotiate, take enforcement action, charge a user fee or accept a payment for the IRS. The taxpayer can opt out of the collection program by written notification.

If the taxpayer has a valid power of attorney is on file for the unpaid tax year(s), the IRS and PCA will contact the taxpayer’s representative instead. If the taxpayer fears the caller is an imposter the taxpayer should contact the IRS. Only individual accounts are affected for now; business account collections begin in 2019.

See the following for more details: • www.irs.gov/businesses/small-businesses-selfemployed/private-debt-collection • www.irs.gov/pub/irs-pdf/p4518.pdf • https://www.ftc.gov/enforcement/rules/rulemaking regulatory-reform-proceedings/fair-debt-collection practices-act-text.

- Video at CollectionAdvisor.com January/February 2018

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What You Need to Know About Blockchain C onsider for a moment, the largest retailer doesn’t own a single store, the largest provider of sleeping rooms doesn’t own a single hotel and the largest provider of transportation doesn’t own a single car.

The world has shifted in recent years to the sharing or collaborative economy – largely enabled by technology and will expand to touch almost all aspects of society in ten years or less.

The biggest change to finance and accounting is expected to be the blockchain, the underlying distributed mechanism for Bitcoin and other digital currencies. Think of the blockchain as a way of keeping track of trusted transactions based on distributed computing sometimes referred to as the Internet of Money. The blockchain is essentially a global cryptography accounting ledger in the cloud.

The blockchain has already provided programmable smart contracts for payouts between two parties once certain criteria has been met, much like collections, providing government the ability to add a small transaction tax built into the blockchain itself.

Positive Impacts of Blockchain

• Increased financial inclusion in emerging markets, as financial services on the blockchain gain critical mass.

• Disintermediation of financial institutions, as new services and value exchanges are created directly on the blockchain.

• An explosion in tradable assets, as all kinds of value exchange can be hosted on the blockchain.

IRS Collections T

he IRS has added two menacing collection alternatives. In addition to assigning collection duties to private collection agencies, some taxpayers could lose their right to a United States passport. For some hard-tocollect bills, the law now requires—rather than just permits—the IRS to use private collectors when: • The tax bill has been assigned for collection, but more than a year has passed without any interaction.

• When more than 1/3 of the statute of limitations has expired, and no IRS employee has been assigned to collect it.

The State Department can revoke, deny or limit passports most to taxpayers the IRS certifies as having a seriously delinquent tax debt over $50,000.

Seriously delinquent tax debt is when a: • Notice of federal tax lien has been filed and all administrative remedies have lapsed or been exhausted.

• Or a levy has been issued.

- Video at CollectionAdvisor.com .com

January/February 2018

• Better property records in emerging markets, and the ability to make everything a tradable asset.

• Contacts and legal services increasingly tied to code linked to the blockchain, to be used as unbreakable escrow or programmatically designed smart contracts.

• These contracts are secured in the blockchain as “selfexecuting contractual states,” which eliminates the risk of relying on others to follow through on their commitments.

• Tax collected for the first time by a government via a blockchain.

Unknown Impacts of Blockchain

• It is unregulated and not overseen by any central bank, meaning less control over monetary policy.

• Real-time taxation • A 2016 mayoral candidate of London has suggested implementing technology to upgrade the existing government ledger for land and for the city’s financial and budget records. Because these records are kept permanently, there is a strong possibility (without the blockchain) for them to be altered or faulted.

The current total worth of bitcoin in the blockchain is around $20 billion, or about 0.025% of global GDP of around $80 trillion.

- Video at CollectionAdvisor.com

New Debt Buyer License Required T he State of Oregon has become the first state to adopt a stand-alone license requirement for debt buyers.

A debt buyer who also performs third-party collections will be required to maintain both a debt buyer and collection agency license in Oregon. There are several application requirements including: • Business plan • Organization chart • E & O Insurance • $450 Application Fee • $15 Credit Report for each Control Persons • $36.25 per person FBI criminal background check for officers, directors and owners of over 10%

The Receivables Management Association reports that Oregon has shown a desire to address their concerns regarding program fees, safe harbor protections for early applicants, and clarity regarding when a company must maintain both a debt buyer and collection agency license.

- Video at CollectionAdvisor.com

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“The key is not to prioritize what’s on your schedule, but to schedule your priorities.”

Lonely at the Top? Bearing the Weight of Leadership by Strausser Continued from page 12 thoughtful resolution to those complaints is often a key component of organizational management. We learn from complaints and can make internal policy changes that ultimately create a consumer-friendly environment while maintaining the good reputation of your firm.

Prioritize

At any moment there is a long list of items that need attention in any office. We must continually assess, what is the best project for today. Be sure to regularly review your list of critical issues and move the most pressing and impactful items to the top. Stephen Covey said about prioritizing, “The key is not to prioritize what’s on your schedule, but to schedule your priorities.”

Learn to Delegate

Get the comfortable but mundane tasks off of your desk and empower others to handle them. This can be very difficult to do for a micro manager but the time you will free up

Ratcheting Up your Compliance Management System by Ciskey Continued from page 14 prevent calls to consumers at inconvenient times?

Issue 17 of the Supervisory Highlights reports, released in Spring 2017, doesn’t contain a section specifically related to debt collection industry examinations, but way back near the end of the report on page 26, this gem related to complaint analysis appears: As a data-driven agency, the Bureau has prioritized detecting issues in the market that could result in risk to consumers.

The Bureau has historically incorporated this information about market trends into the risk-based prioritization of examinations. To this end, the Bureau now continuously monitors spikes and trends in complaints. Our automated capability monitors the volume of consumer complaints for all companies named by consumers in complaint submissions.

Our active monitoring algorithms identify short, medium, and long-term changes in complaint volumes in daily, weekly and quarterly windows. Importantly, the tool works regardless of company size, random variation, general complaint growth, and seasonality. (Emphasis added.)

If you read that quickly, read it again. How much time and effort have you put into analyzing your CFPB complaints?

Can you identify short, medium, and long-term changes in your complaint volumes in daily, weekly and quarterly windows?

Think that only large market participants need to be concerned about complaint analysis? Look again: Importantly, the tool works regardless of company size, random variation, general

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can be substantial. Get projects off your desk that others can do.

Rid yourself of time-consuming report generation and analysis. Put others to work in a fashion that makes your job lighter so you can focus on the big stuff.

Your company or department will only be as successful as you allow it to be. To be the big cheese, you don’t have to be a whiz. You just have to recognize what the firm needs. The top gun doesn’t have to fire perfectly every time but has to aim at targets that matter when the bull’s-eye is hit. To be the boss, you have to recognize that every position in the firm is important and that the pathway to success is paved by a cohesive team with common direction. Titles don’t matter, but making the right decisions does. Theodore Roosevelt proclaimed, “In any moment of decision, the best thing you can do is the right thing, the next best thing is the wrong thing, and the worst thing you can do is nothing.”

Until next time, I’m in a collection office near you!

Harry A. Strausser III is the President of Interact Training and Development. He can be reached at harrystrausser@gmail.com.

complaint growth, and seasonality.

Complaint handling is one of the components of a compliance management system. I submit that complaint analysis is as important a function as complaint handling.

The CFPB gives you a head start by publishing the complaint database online, here: https://data.consumerfinance.gov/ dataset/Consumer-Complaints/s6ew-h6mp. It is a large, daunting database, but the tools provided make sorting the database for your own complaints a quick and easy process.

Export your complaints into a spreadsheet or other tool and look at your complaints the way the CFPB does. Sort them by issue — what stands out? Further sort by sub issue — what is there? Look at your daily, weekly, monthly, and quarterly numbers — what happened in a month in which you see a spike? Did you load a new client, or buy a portfolio that was troublesome? Did you know it was troublesome? What are your trends? What did you do about it? What are you going to do about it now that you know?

Many folks in our industry got busy and created a compliance management system back when we first learned of the CFPB’s expectations. It is time to dust off those original documents if you haven’t touched them since then. Start using your CMS documentation more like a playbook than a reference tool. It is clear that is what our regulator expects us to do.

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.

January/February 2018

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WHAT ARE YOU MISSING FROM YOUR LEGAL COLLECTION SOFTWARE?

Legal Software Roundtable

BY JOSHUA FLUEGEL

T

oday’s litigious consumers have increased the legal workload for accounts receivable professionals. With so many accounts requiring legal action, agencies and law firms must know exactly what they need out of their software in order to operate with it harmoniously. To help articulate such requirements, Collection Advisor has gathered the thoughts of vendors to help ensure wise decisions in legal collection software.

WHAT IS SOMETHING COLLECTION/LEGAL PROFESSIONALS SHOULD LOOK FOR IN LEGAL COLLECTION SOFTWARE? CHRIS J. ROBERTS President/COO of Sentinel Development Solutions People should look for a collection platform that can be easily configured to automatically promote the flow of accounts through processes. As the legal profession continues to move toward automation of repetitive functions, much can be done to automatically execute tasks associated with collection related activities including things like filing, managing documentation requirements, and tracking judgments.

CHRIS CAMPBELL CEO of Simplicity Collection Software

Flexibility and portability. Because laws, court documents, regulations and statutes can vary from state to state and even from county to county within a state, it is important to have software that is flexible and configurable to meet a variety of different needs. Aside from selecting a flexible legal software solution, it is important to select a software vendor that understands the legal collection process and provides a software solution that is portable and accessible from virtually anywhere. This makes cases and case information easily accessible from a laptop, phone or iPad while you are in court or meeting with clients. .com

January/February 2018

RANJAN DHARMARAJA CEO of Quantrax Corporation Is it modern? Does it address the problems or infrastructure changes that were not even on the landscape a decade ago - Security, compliance, the millennial paradox, mobile technology and the changing face of consumer contact? Has the collection platform moved away from “debt collection” to customer service and information management?

After all, isn’t that what today’s collection industry is about?

ASHLEE HYDEN Director of Marketing at DAKCS Software Systems Collection professionals should look to find a software provider who focuses on the legal facets of the accounts receivable and collections process, including the ability to perform the following functions directly within the software: 1. S torage of necessary data needed to track legal processes in your business allows immediate access to integral data points enhancing workflow maintenance, streamlined tracking, and automation.

2. Ability to track important dates applied to each suit and court proceeding such as the date filed, date served, and judg-

ment date provides proof and compliance for each step in the legal process.

3. Itemization, reconciliation, and billing capability for legal costs associated with each suit are core to maintaining an organized and efficient process for legal accounts.

4. Integrated legal appointments calendar in the system with reminders/ticklers provides a fluid active schedule for follow-up dates that improves staying on track and on time.

5. Enhanced flexibility on interest calculations to accommodate tracking pre and post judgment interest and applying appropriate fees associated with each suit.

6. Configurable integrated document design tool in the software to handle all court specific documents. This design tool offers the opportunity to custom design documents and letters needed for specific legal cases and to customize based on specific client requests.

7. Centralized document repository to store and easily retrieve important documents, including electronically filing court records, proceedings, evidence images for a more efficient response time.

Continued on page 24

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“Ability to track legal case from beginning to end.”

Continued from page 23 By having a legal collection software that provides the above functionality within the collection package, your business will have the ease of access and ability to track a suit and legal case from beginning to end by allowing users of the software to store and customize the data in one centralized location.

KURT BAESE President of JST We always recommend to evaluate the compliance needs of your firm, and to make sure the software you utilize can manage these needs.

CHRIS MESSER CEO of Hubbard Systems There are five pillars to look for in a legal collection software package. These are adaptability, integration, accounting,

analytics and company leadership. The collection industry is in constant fluctuation, and the agency/firm must be able to adapt to the changing needs of their clients and government regulations. The collection software must be able to change with industry requirements, and the changes have to be easy to integrate into the agency/firm’s processes without too much involvement from the software vendor. The collection software must also have a strong accounting package that is fully integrated into the software and not simply an after-thought or add-on. This pillar is often overlooked by professionals in this industry. But because of increasing fiduciary responsibilities for attorneys, one has to evaluate the accounting packages in the software. The fourth pillar for proper evaluation of collection software is the analytics package offered. Every software vendor has some reporting options, but those basic options

just do not suffice in this industry anymore. The agencies/firms must be able to ad-hoc, schedule, or on-demand generate reports for clients and government entities.

Due to the overwhelming reporting requirements from multiple channels agencies/ firms have to deal with, the analytics/reporting engine must be available and usable to more than just the agency/firm’s technical department. The fifth pillar, overlooked most often, is the leadership of the software vendor. The leadership of the software vendor is of vital importance. The agency/firm needs to feel like they have a partner that will work with them to get through the constant change of the industry. The agency/ firm must feel like they have a partnership with mutual respect and open lines of communication. If the leadership on both sides is not “all-in” together, the partnership will struggle and ultimately end in failure for both sides.

WHAT IS IMPORTANT TO REMEMBER WHEN INTEGRATING LEGAL COLLECTION SOFTWARE INTO AN AGENCY/LAW FIRM? ASHLEE HYDEN Director of Marketing of DAKCS Software Systems

KURT BAESE President of JST

CHRIS J. ROBERTS President/COO of Sentinel Development Solutions

Having built-in tools designed for the legal collection space is key to fluidity and business growth. These features include the ability to track and manage court dates and fees on every activity, flexible screen, report and document design to efficiently work accounts, as well as the automation to improve productivity, ensure compliance, and quality in your workflow.

If you are in need of moving data from an existing platform to a new one, be sure to take the time to outline and specify a detailed conversion plan with your new provider. It also is a good time to reevaluate your internal procedures and workflows, and as a result set these up thoughtfully in your new system.

One of the most important things about integrating collection software into an agency or law firm is that the software vendor has experience building automatic, flexible interfaces that can be readily modified and supported over time and backed by a readily available support staff.

CHRIS MESSER CEO of Hubbard Systems It is important for the agency/firm to work with the software vendor to have clear requirements of internal human resources needed, hardware and software required, and current workflow for a successful integration. If the agency/firm has any internal resources that are required but not available, they should reach out to the software vendor to arrange additional resources as needed to ensure a successful integration.

24

RANJAN DHARMARAJA CEO of Quantrax Corporation Technology will never solve problems. People must do that. Integrating new software into old processes will only do what you were doing yesterday, using a different product.

Think Uber – is there a new and better way to manage a process that has not significantly changed for many years? Ask those questions and then, consider integrating new technology into your operation.

CHRIS CAMPBELL CEO of Simplicity Collection Software Develop your plan for success and then ensure that the software you select will help you achieve that plan in an efficient manner. Make sure you have a firm understanding of the software you will be using, its functions and features, and then rely on your software provider’s support staff to help you customize and automate critical strategic processes in order to reduce staff load and time making your business more efficient and profitable.

January/February 2018

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LEGAL COLLECTION SOFTWARE COMPARISON CHART

PRODUCT NAME

Beyond ARM

CollectMax

Collection PartnerÂŽ

eCollections

RMEx

Simplicity Collect

COMPANY NAME

DAKCS Software Systems

JST

Hubbard Systems Inc.

Sentinel Development Systems

Quantrax

Simplicity Collection Software

Accounts can be related across clients (or sub-clients) Automated phone dialing Designs custom reports on operator level Online, real-time coaching Goals feedback in real-time Secure and customizable remote access for collectors Secure and customizable remote access for debtors Secure and customizable remote access for clients Champion-challenger tools

Yes Yes Yes No Yes Yes Yes Yes Yes

Yes Yes Yes No No Yes No Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes No

User-definable client access interfaces

Yes

Yes

Yes Yes Yes No No Yes No Yes No Other-Standard & Multiple Forwarder

Yes

Yes

Yes

Integration with Crystal Reports

No

Yes

Yes

Yes

Yes

No

User-defined account matching criteria User-defined balance buckets User-defined payment types Account and related tables can be extended

Yes Yes Yes Yes

No No Yes Yes

Yes No Yes Yes

Yes Yes Partial Yes

Yes Yes Yes No

Yes Yes Yes Yes

Integration with pre-legal collections Integration with Microsoft Word Tracks 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

Yes No Yes Yes Yes No No Yes No Yes Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Yes No Yes Yes Yes Yes Yes Yes No Yes Yes Yes

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Track party judgments

Yes

Yes

Yes

Yes

Yes

Yes

Case tasks scheduled automatically Multiple check requests based on court requirements Multiple legal documents based on court requirements

Yes Yes Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes No Yes Yes

Yes Yes No Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes No Yes

Yes Yes Yes No No

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

Yes Yes Yes Yes Yes

GENERAL FUNCTIONALITY

LEGAL COLLECTIONS FUNCTIONALITY *

RECOVERY FUNCTIONALITY Post-charge-off recovery Agency/attorney management Asset sales Automated file processing Repossession tracking

PRE-CHARGE-OFF FUNCTIONALITY Dispute/deduction codes can be assigned Identifies, tracks problem invoices Coded problems separate from other receivables Customer and invoice-level notes Electronically reproduces/transmits invoices

* All systems permit related accounts viewed simultaneously, customized formatting of statements, will set up clients as either gross or net remittance, recommends goals and scripts for collection calls, generates automated letters by client with flexible triggers, and built-in collection agency templates.

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

‘

Buyers Guide

Analytics & Data

Lyons Commercial Data Financial Institution & On-Demand Verification lyonslive.com whopkins@autoscribe.com 800-684-0388 Lyons Commercial Data helps processors, financial institutions, and businesses optimize their ACH processes, manage risk, and mitigate fraud by providing quality data via online tools, downloadable databases, and a web services API.

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.

InterProse

InterProse WebAR ACE interprose.com/collection-advisor aaron.reiter@interprose.com 844-244-1135 Debt Recovery Software Solutions through a patented Virtual Agent Collector and a true, web-based collection platform, open to third-party integrations and packed with process automations.

Quantrax Corporation Inc.

RMEx quantrax.com marketing@quantrax.com 301-657-2084 Quantrax is a high-end collection technology company that has marketed and supported an intelligent collection software platform for over 25 years.

Simplicity Collection Software SimplicityCollect Collection Agencies simplicitycollectionsoftware.com sales@simplicitycollect.com United Collection 866-791-0224 Bureau, Inc. As an industry leader, Simplicity is the only software pro 1st and 3rd Party vider to offer a web solution with unlimited users, clients, Comtech Systems Collections accounts, and custom fields at an affordable price!

Collect! ucbinc.com Credit and Debt ssharma@ucbinc.com Collection Software 954-236-6027 collect.org | info@collect.org UCB, Inc. provides national debt programs for creditors in 800-661-6722 all markets from fully-secure high performance collection Collect! combines ease of use with total integration centers located in the U.S. and Latin America.

January/February 2018 of functions. Accounts are efficiently tracked from Volume 18, No. 1 the time you receive them until activity is concluded and they are closed. Collect! keeps track of critical Collection Software Editor-in-Chief information automatically. Total integration provides Joshua Fluegel for seamless and accurate month end invoices and CDS Software josh@collectionadvisor.com statements with full account histories.

CollectOne Editor collectone.com T. Steel Rose, CPA, ACG Comtronic info@collectone.com Debtmaster 888-816-3333 editor@collectionadvisor.com debtmaster.com CollectOne is an award winning suite of debt colPublisher 800-414-2814 lection solutions that provides a feature-rich set of Angie Rose Debtmaster®360 gives you a cloud hosted, costautomated business processes designed to minimize angie@collectionadvisor.com effective, flexible, secure, collection solutions that helps costs and maximize results. you manage compliance and provide quality service for The opinions given by contributing authors are their Clients and Debtors.

CODIX own and not necessarily the opinion of our staff iMX Collection, and ownership. All trademarks used DAKCS Software

Legal and Recovery Solution are the property of their respective owner.

Systems codix.us/debt_collection Beyond.Net bquinn@codix.us Collection Advisor (ISSN# 1556-0813) dakcs.com | sales@dakcs.com 404-790-0998 is produced six times a year by Abide Media, 800-873-2527 iMX is a complete centralized debt collection and P.O. Box 92342, Southlake, TX 76092, DAKCS Software Systems has been an industry leader recovery software solution. Based on the latest 888-610-1144. for over thirty years. Headquartered in Ogden, Utah, technologies, iMX Debt Collection includes all the Standard Mail postage paid at Sussex, WI 53089. most advanced business functionalities supported by DAKCS provides a one stop shopping solution for a ©2018 All Rights Reserved diverse client base. DAKCS is committed to providing native tools.

Magazine Publishing Group, Inc. their customer community with all the tools they need to succeed in the ever changing ARM business, today and in the future.

26

January/February 2018

.com

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

Collection Support Services Applied Innovation Inc. PayStream 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.

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

Electronic Payments PaymentVision Electronic Payments Processing Solutions paymentvision.com whopkins@autoscribe.com 800-345-7243 PaymentVision offers a wide range of secure, PCI Level 1 certified payment portals and solutions; giving their customers the ability to accept all forms of payment.

Anytime, anywhere.

Predictive Dialers Noble Systems Corporation Contact Center Technology

noblesystems.com info@noblesystems.com 404-851-1331 Noble Systems Corporation is a global leader in customer communications, providing innovative premise and cloud solutions for Contact Center, Workforce Management and Interaction Analytics technologies.

Skip Tracing IDI Inc. idiCORE ididata.com | sales@ididata.com 855-842-1410 Trusted for over a decade by collection agencies and collection attorneys. IDI provides fast, accurate and cost-effective consumer verification and skip-tracing solutions via online, API, and batch processing.

Reduce Cost, Not Quality.

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

Melissa Data Listware melissa.com greg@melissadata.com 800-542-7434 Melissa offers solutions that empower collection professionals with the right-party contact information for successful collections and account management efforts.

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.

Virtual Collections Applied Innovation Inc. PayStream

.com

January/February 2018

27

COLLECTION TECHNOLOGY SHOWCASE 20,000 Collection Professionals Seeking Technology Solutions

Advertise Today | Call Angie at 888-610-1144

Collect Large, Pay Light.

Flexible. Scalable. Comprehensive. Modular. Now with Microsoft SQL Server based options. Software for first party, third party and specialized portfolio collections.

Call 1-800-661-6722 for a consultation Collect.org

GET DISCOVERED

Learn more. Contact Angie today. 888-610-1144

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January/February 2018

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RMEx

Mobile Suite

Quantrax

WHY IS THE ONLY COLLECTION PLATFORM THAT HAS USED ARTIFICIAL INTELLIGENCE WITH SPECTACULAR RESULTS, THE INDUSTRY'S BEST KEPT SECRET AFTER 25 YEARS? The collection industry spends millions of dollars a year maintaining and enhancing core collection platforms. Software companies that failed to evolve, can not meet today's demanding requirements.

Against great odds and without a great deal of support from the industry, one company has quietly persevered.

Their innovative, intelligent technology has given small and large companies stunning gains in productivity, automation and powerful machine thinking that this industry has never seen.

In a modern era, the call for pioneering solutions to old problems has never been greater. Are you tired of hearing and reading about dated technology that has overstayed its welcome? Call us if you want to be amazed.

(301) 657-2084 | www.quantrax.com | marketing@quantrax.com

CORPORATION

Receivables Management Expert

Collections MadeEasy Easy Collections CollectionsMade Made Easy

With Right-PartyContact Contact Data With WithRight-Party Right-Party Contact Data Data NAME

NAME NAME

Listware® Listware® Listware®

@ @ Listware Listware ensures ensures you you have have right-party right-party contact contact Listware ensures you have right-party contact information information forfor successful successful collections collections and and information for successful collections and account account management management efforts. efforts.

account management efforts.

This This simple-to-use simple-to-use data data cleansing cleansing tool tool helps helps This simple-to-use datacurrent cleansing tool and helps you you locate locate and and maintain maintain current address address and you locate and maintain current address telephone telephone numbers numbers forfor less less than than aa penny penny a aand telephone record! record! numbers for less than a penny a

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Contact Contact data data forfor 140 140 million million households households && Contact data for 140 million households & 1919 million million businesses businesses

19 million businesses Multiple Multiple data data sources sources updated updated regularly regularly Multiple data sources updated regularly 15+ 15+ years years proprietary proprietary Change Change ofof Address Address records records 15+ years proprietary Change of Address record Different Different access access methods: methods: Online, Online, Excel Excel and and Different access methods: Online, Excel and Salesforce Salesforce Salesforce

Available Availablein: in:

Available in: Listware® Listware® Online Online

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Start for Free www.melissa.com/clean www.melissa.com/clean www.melissa.com/clean Melissa MelissaData Datais isNow NowMelissa.

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