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Receivables Industry Leaders Share COVID-19 Strategies, Successes, and Lessons Learned

Receivables Industry Leaders Share COVID-19 Strategies, Successes, and Lessons Learned

This week, Ontario Systems hosted its third weekly COVID-19 webinar for third-party collectors, “Voices from the Trenches: How Leaders Are Leading During the Crisis.” I had the pleasure of speaking with three agency executives who shared their experiences and perspectives on a variety of operational concerns related to COVID-19.
Joining us on the panel were:

 

Like all of us, these leaders and their organizations were forced to adapt quickly to COVID-19—not to mention a shifting legal landscape that’s been particularly challenging for the receivables industry.

 

How have these leaders managed to successfully navigate the COVID-19 crisis? Here are some notable excerpts from our conversation, in the panelists’ own words.

 

A Study in Contrasts: 30 Days Ago vs. Today

David White, Performant

Generally speaking, our business was not remote. We were close to 100%  brick and mortar. The clients we partner with didn’t have a desire to maintain remote workers.

 

So fast forward to the pandemic: we’re 95% remote in our capabilities today. We’re very lucky to have client partners that have moved very quickly with us to migrate our operations to remote capacity. We’re very excited to be where we are today, and I think we’ve adapted pretty well to the situation.

 

Laura Jensen, ARC

Over the past couple of years, we’ve worked towards having our staff going remote. So our transition was fairly easy. We have about 95% of our staff currently working remote. We have some essential services in our office—payment, posting mail, HR, and some IT support.

 

We had a mixed experience [with companies we outsource to]. Some of our servicers had intended to offload calling to a remote site in the Philippines, and the Philippines went on lockdown before the U.S. So that pandemic plan didn’t bear out. This has definitely challenged a lot of people’s business continuity plans.

 

Tim Haag, State Collection Service

We’ve been working with remote staff, both admin and reps, for about four or five years now. So we had some experience—obviously not to where we’re at today, but we had roughly 80 people working remotely prior to COVID-19. Now, I would say 85-90% of our staff [of nearly 500 people] is remote. I’m so proud to say all that’s working well.

 

When communicating with consumers, the big thing is scripting. We got on that right away, started changing scripting, making less outbound calls, less texting. And I think the main thing is we continue to listen to the consumer and do what’s right to solve problems.

 

Meeting the Challenge of Managing Remote Workers

David White, Performant

We had individuals on the admin side and management side who were working remote, but to transition our entire staff remotely meant we had to adapt them pretty significantly to meet our clients’ requirements. We’ve got some clients at the government level that have very high expectations for data security.

 

Think about all the different digital assistants around your house—your Alexa, your Google, your smartwatch, your phone. When we’re working and we’re in range of those types of digital assistants, how do we ensure our customers’ data are not being picked up? How do we not have risk and exposure? We had to adapt policy and procedure wise.

 

Tim Haag, State Collection Service

We utilize speech analytics. We’re monitoring in a live version, so all the supervisors know exactly what’s taking place on all those calls as they’re happening. We also have the use of Artiva Magnify™, so we can jump in and listen into calls, coach calls, text messages to the representatives, or ultimately take over the call.

 

Prior to COVID-19, for those who did get a chance to work from home, we expected them to have a 5% improvement in productivity, If they didn’t do that, they were asked to come back into the office until that productivity came back. As time goes on, as people get more comfortable working from home, we hope to see that productivity increase with all the rest of the staff.

 

Engaging Consumers and Patients Suffering Hardships

Laura Jensen, ARC

We’ve consistently pushed our servicers to honor hardship policies and make sure their hardship policies are adjusted to the extent they need to be for people who are ill or out of work for COVID-19.

 

David White, Performant

It’s about trying to find the right payment plan for these individuals. That may mean pushing out those payment plans for a period, it may be extensions, it may be reductions in what those payoffs may be. Most of our clients have been very, very willing to work with us as it relates to finding the right solution for consumers.

 

Tim Haag, State Collection Service

Consumers, when we do reach out to them, are very thankful that we’re offering up solutions right away. “Hey, I see you’re on a payment plan. Do you need to defer this plan for the next 60 days?” They’re kind of surprised, like, “Wait—you’re on my side. You’re here to help. I really appreciate your reaching out.”

 

Keeping Remote Teams Connected and Energized

Tim Haag, State Collection Service

For a supervisor to communicate with their representatives or the agents, we utilize Microsoft Teams. So now we’re doing team meetings and individual one-on-ones using that platform.

 

We’ve also been using a gamification system for about two or three years. This helps keep the  excitement piece that exists inside the office, we’re still able to do that, and they can track their stats. So they can still have friendly competition. We’ve been throwing some extra carrots out there, and that’s been a lot of fun.

 

David White, Performant

We’ve got a very cool intranet that we utilize. The intranet allows us to do a ton of different posts on a daily basis of updates, shout outs to individuals, our CEO posts, articles once a week of feedback, what’s going on in the business, the industry—what we’re doing on all those different types of things.

 

Also, as part of this intranet, we can do group discussion boards that work very well. So we’ve got email, we’ve got chat, but this group discussion board is for when we have situations that come up that someone’s like, “Okay, is this unique? I’ve talked to this person, this is what was said, how do we handle this?”

 

Managing Compliance and Client Communications

David White, Performant

Our general counsel manages the process for us. We’ve got a moving document that’s living and breathing based on all the changes coming out of COVID-19, so that document is reviewed on a regular cadence in leadership meetings. Originally, we were meeting daily, but now we’re doing it every other day—a pandemic team call with the key stakeholders within our company.

 

We’ll cover all the changes that happened in the previous 24 hours. We’ll communicate what direction clients have provided us relating to that. Then we’ll typically provide guidance to our account management team, sales, and business development team about where we stand with this and the changes we’re making. And then we’ll say, “Convey this to the client and let them know what we’re going to be doing on our side, and see if that lines up with their expectations.”

 

Tim Haag, State Collection Service

You would actually think that [healthcare providers] aren’t worried about the day-to-day collections environment, but now they are, because there’s nobody in hospitals right now, and they’ve cancelled all surgeries. So their revenue is going down. Cash is extremely important to them right now. So we’re getting more of their attention.

 

We put together right away a COVID-19 response team. We meet every morning . . . for about 30 minutes to talk about communication that we’re going to send to our clients. We actually came up with a new procedure for our compliance change management process. That goes to our general counsel, and from there, he makes the change. When all this settles, we can go back and make sure all those changes were back to normal.

 

Lessons Learned

Laura Jensen, ARC

The biggest lesson I’ve taken away is management related: show up every day, show up for your staff, show up for your company. For me to do that, it’s getting up and having a positive attitude. It’s getting ready and being present. There’s a lot of chaos, and everybody’s scrambling and nobody knows what to do, but show up. Be present. Be a leader.

 

My second [lesson] is, always have your best staff. I have the best staff, and I trust my staff implicitly. I think that has been a huge help in getting through this.

 

Tim Haag, State Collection Service

I think continuing that communication with [employees]—”Hey, guys, it’s going to be alright; we’re going to get through this”—it means a lot. And I have been focused more not on the day-to-day things now, but let’s see what happens after this. So let’s not worry about tomorrow, but let’s start thinking about next month, six months from now, a year from now, and how we can come out on top.

 

David White, Performant

In a limited time, we’ve had to be remote. Hopefully our clients are understanding that this is an opportunity for the long haul, not just through the COVID-19 situation—that after we get through this, there’s an opportunity for us to adapt our workforce and adapt our offerings. I’m not advocating for 100% remote, but some flex opportunity for us to be effective.

 

Catch Up on Previous Discussions, and Join Us Next Week

Our past COVID-19 weekly webinars were full of valuable insights and tips related to compliance management and business continuity. You can find detailed summaries with links to the webinar replays in these recent blog posts:

 

You can also listen to this week’s webinar, “Voices from the Trenches: How Leaders Are Leading During the Crisis,” in its entirety. Click here to download the recording.
Be sure to register for next week’s COVID-19 crisis management webinar, “Product-Centric Solutions for COVID-19 Challenges.” We’ll explain how the Ontario Systems solutions you currently have in place can help smooth the transition to normal operations as we emerge from this crisis. It’s a critical (and welcome) discussion you won’t want to miss.

 

Info and Insights You Won't Want to Miss

On the OS Blog, we aim to give you the right mix of high-level views, tactics, and tools you can use to optimize your collection operations and results. Subscribe today for a steady stream of practical, empowering content delivered to your inbox weekly.

Disclaimer: Ontario Systems is a technology company and provides this blog article solely for general informational and marketing purposes. You should not rely on the content of this material for any other purpose or as specific guidance for your company. Ontario Systems’ advice, services, tools and products described herein do not guarantee compliance with any law or industry standard. You are ultimately responsible for your own company’s actions and compliance efforts. Because everyone’s situation is different, you must consult your own attorneys, accountants, and/or other advisors to obtain specific advice on your company’s compliance, legal, tax, regulatory and/or other business needs. Despite Ontario Systems’ efforts to provide current and up-to-date information, you need to recognize that the information contained herein may become outdated quickly and may contain errors and/or other inaccuracies.

© 2020 Ontario Systems, LLC. All rights reserved. Information contained in this document is subject to change. Reproduction of this publication is not permitted without the express permission of Ontario Systems, LLC.

A Challenge for ARM Leaders: Finding Opportunities in the Chaos

A Challenge for ARM Leaders: Finding Opportunities in the Chaos

Since President Trump declared a national emergency due to COVID-19, ARM leaders across the country have been forced into a minefield of swift decisions to continue operating, meet client requirements, and stay compliant with state restrictions. The last...

A Challenge for ARM Leaders: Finding Opportunities in the Chaos

A Challenge for ARM Leaders: Finding Opportunities in the Chaos

Since President Trump declared a national emergency due to COVID-19, ARM leaders across the country have been forced into a minefield of swift decisions to continue operating, meet client requirements, and stay compliant with state restrictions. The last five weeks have undoubtedly been a whirlwind of chaos in these unchartered waters.

But as I speak to leaders, I’m beginning to detect a sense of calm as companies see their response plan settling into a new operational rhythm.

As the ARM industry operates under this new normal and prepares for a wave of increasing delinquencies, we have a unique opportunity to take a step back, evaluate our business as a whole, and ask ourselves, “What should our business look like post COVID-19?”

How You Care for Your Employees Today Will Follow You Post COVID-19

Because the ARM industry relies predominantly on human capital, its employee base is often at risk during times of crisis such as the Great Recession and the global pandemic we’re facing now. Even without a crisis, employee attrition has long plagued the ARM industry.

I believe now is a good time to take meaningful steps to address this issue.

We are working through a pivotal moment in our history, which will likely be defined by the contrast between pre and post COVID-19. Your future job applicants will be interested in understanding how you responded to this pandemic and how you plan to protect your employees in the event of future pandemics.

It’s critical that you determine now how you’ll handle staffing decisions in the coming days and long after COVID-19 recedes. Here are a few things you’ll want to consider.

If debt collection activity has decreased, identify ways you can repurpose your systems and employees.

Most ARM companies could easily convert their businesses into any call center operation. Start by reaching out to your existing clients and offering them customer care services, and then put your sales team to work on new opportunities. Don’t be afraid to think outside the box; whatever new opportunities come your way will help you diversify and strengthen your business.

This is a great time to invest in your employees’ education and professional growth.

There are opportunities across the ARM industry and beyond that offer free training on a multitude of subjects. In addition, industry conferences are transitioning to virtual conferences, which gives you an opportunity to expose more employees to the collaboration and thought leadership these events support.

If you must reduce staff, think about ways to continue supporting them as you work through rebuilding your company.

I’m inspired to see companies that have furloughed or laid off workers opt to continue paying for their health benefits. At a minimum, consider providing personal recommendation letters and referrals as well as guidance on industry training opportunities and certification programs that may help the recently unemployed further their careers.

Defining Your Company’s “New Normal” May Be the Difference Between Surviving and Thriving

As ARM companies settle into their new routine—i.e., leading a mostly remote staff—leadership teams are asking, “How do we return to ‘normal’?”

My question for you is, what constitutes “normal”? Should you go back to the way things were pre COVID-19? I question whether creditors will even let their third-party service providers return to business as usual.

If you’re in a position to lead your company to the next level, I have a few thoughts about where you might focus during this chaotic situation to build a stronger company from a business continuity standpoint. A great first step would be to expand your company culture by embracing a hybrid approach of working from home and providing more self-service options for consumers.

Conquer your fear and embrace digital channels

The ARM industry has been talking about text messaging for several years, but adoption is still limited. Establishing a compliant and effective text messaging program begins with obtaining TCPA consent and express consent to text as well as E-SIGN consent if you’re going to send out legally required written disclosures.

This is where companies often lose heart, because they don’t see easy options to obtain the consent needed to feel comfortable with this communication method.

The truth is, digital communications can actually be simpler from a compliance management standpoint—and more essential to business—than many ARM leaders believe.

The COVID-19 pandemic has put 80% of Americans under stay-at-home orders, which presents a unique opportunity to engage consumers and learn about their communication preferences. Capturing the required consent for email and text messaging communications in the future helps the consumer as their situation changes. It also sets your company up for more effective communication channels as stay-at-home orders begin being lifted.

Introduce or expand self-service options

Take this time to evaluate how effective your consumer-facing website is for your business. Is it merely a storefront, or does it help drive consumer engagement and payments?

Your website allows you to connect with consumers 24/7—and, as a result, optimize your collection efforts. As you consider consumer demands for convenience and look ahead to the post COVID-19 era, I recommend integrating your website with a consumer portal where consumers can manage their account, make payments, request information, file a dispute, or send a complaint.

Lean into work-from-home arrangements

Fostering a work-from-home culture has been traditionally difficult across the ARM market. But as the pandemic risk heightened, financial service providers were thrust into embracing it quickly. As you evaluate your business structure moving forward, you may want to consider implementing a long-term work-from-home environment.

It’s widely understood that work flexibility is a top priority among millennials and the upcoming generation Z. The best way to appeal to these job seekers, and retain them long term, may be to offer a work-from-home option. Having a work-from-home structure can also help your business weather future disaster or emergency declarations more easily.

As you work through managing your remote employees’ productivity and compliance, take this time to document what works and what doesn’t so you can begin mapping out a work-from-home plan for your business. It’s entirely possible that the post COVID-19 business world may look less like beautiful brick-and-mortar buildings, and more like small offices for essential onsite employees and virtual meetings with mostly remote staff.

When The Crisis Ends, Be Ready to Accelerate Your Success

As you begin the journey of discovering what’s next for your business, I encourage you to use this turning point to push past your comfort zone. Look for new ways to incentivize your employees, and establish new markets to serve. Streamline your processes and communicate more effectively with consumers.

Take these steps now, and you’ll be able to hit the ground running in the post COVID-19 era.

Info and Insights You Won't Want to Miss

On the OS Blog, we aim to give you the right mix of high-level views, tactics, and tools you can use to optimize your collection operations and results. Subscribe today for a steady stream of practical, empowering content delivered to your inbox weekly.

Disclaimer: Ontario Systems is a technology company and provides this blog article solely for general informational and marketing purposes. You should not rely on the content of this material for any other purpose or as specific guidance for your company. Ontario Systems’ advice, services, tools and products described herein do not guarantee compliance with any law or industry standard. You are ultimately responsible for your own company’s actions and compliance efforts. Because everyone’s situation is different, you must consult your own attorneys, accountants, and/or other advisors to obtain specific advice on your company’s compliance, legal, tax, regulatory and/or other business needs. Despite Ontario Systems’ efforts to provide current and up-to-date information, you need to recognize that the information contained herein may become outdated quickly and may contain errors and/or other inaccuracies.

© 2020 Ontario Systems, LLC. All rights reserved. Information contained in this document is subject to change. Reproduction of this publication is not permitted without the express permission of Ontario Systems, LLC.

ARM Leaders, Your Compliance Management System Will Soon Face its Ultimate Test

ARM Leaders, Your Compliance Management System Will Soon Face its Ultimate Test

Since the Dodd-Frank Act was passed, you’ve no doubt worked tirelessly to build a comprehensive compliance management system (CMS) that meets the Consumer Financial Protection Bureau’s (CFPB) expectations and those of your clients. Regardless of whether your CMS has been tested by a third-party risk assessment, a CFPB examination, or consumer litigation, I think it’s fair to say none of us could have predicted a global pandemic that would put CMS’s to the ultimate test.

As I write this, there are several bills circulating in Congress that could have big implications for the ARM industry. Almost daily, states across the nation are imposing their own rules in response to the COVID-19 pandemic. In nearly every conversation I have with ARM leaders, I can sense the anxiety.

But here’s the good news. The fallout from the 2008 financial crisis handed us a new regulatory body that has indirectly prepared the ARM industry for this unprecedented event. You just need to make sure that as you transition more of your staff to remote work, your compliance controls follow.

5 Keys to Managing Compliance in the COVID-19 Era

Boards of directors and executive leaders across the industry have been thrust into a sea of new operational and compliance challenges they might not have contemplated. Decisions are often made through the lens of quick risk analysis and business continuity.

However, as you weigh the business impact of your operational response to COVID-19, you must also evaluate the associated compliance risks. You need to be proactive in mitigating consumer harm risks to avoid another windfall of regulatory actions and litigation. Here are five ways your CMS can help you mitigate those risks.

1. Track all compliance metrics closely, and COVID-19 metrics separately.

Board of Director and/or executive reporting has likely increased since the beginning of the pandemic. In your meeting agendas and minutes, be sure to document compliance metrics including but not limited to:

  • Complaint trends
  • Dispute trends
  • Call monitoring trends
  • Compliance audit trends
  • New state restrictions
  • Federal regulatory changes
  • Emerging risks due to the COVID-19 impact
  • Audit results
  • Testing results of new workflows

I would encourage you to separate COVID-19 related metrics from your typical reporting to help adequately analyze and respond to the compliance risks related to this specific crisis.

2. Test all workflow changes before implementing them widely.

Leadership may be eager to change systemic workflows in response to client, state, or other restrictions imposed during this fluid situation. When these changes are made, don’t skip the critical step of testing. The unintentional consequences of any one change could cause your company greater harm in the long run.

3. Be sensitive to consumers’ personal hardships.

As consumers face income loss or uncertainty, experience COVID-19 personally, or care for someone else, ARM companies may see an increase in consumer complaints. It’s important that you evaluate your response to these complaints to ensure that they are handled with empathetic care.

4. Ensure remote agents are adequately managed and supported.

With a significant portion of the industry working from home, your compliance monitoring tools should be evaluated to ensure you’re getting a meaningful picture of what your agents are hearing and how they’re responding to consumers.

Practical steps you might take include:

  • Changing up your word/phrase search in your speech analytics tool
  • Manually reviewing more calls
  • Increasing live call reviews utilizing the whisper feature
  • Providing immediate feedback to agents

In addition to stepping up call monitoring and coaching, you’ll want to ensure proper status changes, notations, and updates are being made in accordance with your policies and procedures.

5. Shore up your auditing controls.

Changes in your employees’ work location may also put a strain on your auditing controls. It’s more important than ever to have those controls in place for incoming consumer communications, payment processing, call frequency, credit reporting, and dispute response management as well as any new systemic processes put in place as part of your COVID-19 response.

In These Challenging Times, Stay Focused on Your Future

COVID-19 is not the first pandemic our nation has experienced, nor will it be the last. As you work to address current challenges and concerns, consider how changes you’re making today related to policies, procedures, and training can help you build the foundation for a stronger, more successful business long term.

Info and Insights You Won't Want to Miss

On the OS Blog, we aim to give you the right mix of high-level views, tactics, and tools you can use to optimize your collection operations and results. Subscribe today for a steady stream of practical, empowering content delivered to your inbox weekly.

Disclaimer: Ontario Systems is a technology company and provides this blog article solely for general informational and marketing purposes. You should not rely on the content of this material for any other purpose or as specific guidance for your company. Ontario Systems’ advice, services, tools and products described herein do not guarantee compliance with any law or industry standard. You are ultimately responsible for your own company’s actions and compliance efforts. Because everyone’s situation is different, you must consult your own attorneys, accountants, and/or other advisors to obtain specific advice on your company’s compliance, legal, tax, regulatory and/or other business needs. Despite Ontario Systems’ efforts to provide current and up-to-date information, you need to recognize that the information contained herein may become outdated quickly and may contain errors and/or other inaccuracies.

© 2020 Ontario Systems, LLC. All rights reserved. Information contained in this document is subject to change. Reproduction of this publication is not permitted without the express permission of Ontario Systems, LLC.

Collection Policies and Procedures: 4 Tips for Managing Risk on the Front Line

Collection Policies and Procedures: 4 Tips for Managing Risk on the Front Line

In the accounts receivable management (ARM) industry, policies and procedures aren’t just helpful to have. They’re critical protection for collection agencies, whose compliance risks are myriad and ever changing. Policies and procedures are of little use, however, if they’re inadequate, outdated, or not consistently followed.
 
When policies and procedures aren’t serving their purpose, ARM companies face all sorts of potential blowback. In addition to loss of business, worst-case scenarios can include regulatory fines, CFPB audits, civil investigation demands, and litigation.
 
As an ARM business leader, how can you ensure your policies and procedures are effective and your collectors are following them to the letter?
 
In a recent group discussion hosted by Mike Gibb at AccountsRecovery.net, I joined two of my industry peers—Alicia McKeighan, Chief Compliance Officer at Afni; and Paige Tortorich, Internal Audit Manager at ERC—to tackle this question in some detail (you can access the webinar here). Below, I’ve highlighted four major areas we believe collection agencies should focus on in their efforts to manage compliance risk day to day.
 
 
 

1. Prioritize Monitoring, Reviews, and Updates

A culture of compliance, where all stakeholders are on board and on the same page, is essential for mitigating compliance risk. Senior leadership, compliance officers, operations leaders, and collection agents all bear responsibility for developing, fine-tuning, and executing policies and procedures consistently and effectively.
 
To build a culture of compliance, you must establish processes and schedules for measuring and improving your policies and procedures—both their effectiveness (how well they’re working on the front line) and their relevance (whether they align with current laws and regulations). For smaller agencies with limited resources, it may be worth bringing in a third party to help with monitoring and auditing rules.
 
Policies, which should clearly outline what’s acceptable and what isn’t, should be reviewed annually. Changes should happen only as a result of changes in the law or newly identified litigation risks, and then only after a thoughtful review and risk analysis.
 
Procedures, or the steps employees must take to comply with existing policies, are more fluid. They can be changed as needed to improve their effectiveness or when new technologies or other initiatives alter workflows. Agents should be encouraged to weigh in with suggestions, so they stay engaged and understand the important role they play in managing compliance. When feedback can’t be acted on (as agents don’t always have the full context for a given procedure), agents should always understand the reason(s) why.
 
Ground Level: Compliance Gap Assessments
Compliance gap assessments are designed to ensure compliance with policies and procedures on the front line and throughout the organization. Payment processing, reporting structure, organization, compliance management, and other aspects of your operation should be audited regularly—by someone not in operations, per the CFPB—with the frequency of audits determined by the degree of risk posed by noncompliance.
 
From 30,000 Feet: Annual Risk Assessments
Annual risk assessments should include a detailed review of existing policies and procedures to determine whether any need updating to better fit the current legal landscape. An annual risk assessment might also point to the need for training updates, additional controls, or additional auditing and/or monitoring.
 
Who should be responsible for writing/revising policies and procedures?
Stakeholders across the organization, including but not limited to the chief compliance officer, should be involved in the process of writing and revising policies and procedures.
 
If your operations managers are too busy to update policies and procedures, you could:
 
  • Enlist a dedicated document specialist.
  • Have a mediation auditor meet with managers to write procedural changes and get approvals on the spot.
  • Use fill-in-the-blank templates.
Any of these approaches would streamline the process and allow managers to focus more on managing agents’ performance.
 
What if you’ve let assessments slide, or you’ve never had a formal program in place?
If you’re not conducting compliance gap assessments on a regular basis, now is the time to get back on track. Create a schedule and hold yourself accountable. Start by auditing your top three highest-risk items, fine-tune that process, add additional audits and monitoring controls every 6-12 months, and continue building out the program from there.
 
You’ll also want to review your procedures for accuracy. Make sure everyone can easily access them—ideally, in electronic form (see tip #2). Conduct refresher training with your agents and/or members of other departments, and ask questions to test their knowledge.
 
Exception reporting is critical to managing compliance. You need to be sure your controls are in place and working properly. An exception report might be triggered when:
 
  • An agent took a call, but no notes are listed.
  • An agent took a payment but didn’t get a correct address.
  • An agent added a credit card or Social Security number to the notes.
When a procedural violation occurs and correction is needed, operations should be notified right away (automatic notifications are preferable; see tip #4). It’s important to determine whether any trending issues relate to flawed procedures or the need for refresher or updated training.
 
 
 

2. Make Policies and Procedures Easily Accessible

For many people, the words “policy” and “procedure” bring to mind dusty manuals sitting on a shelf. But reliance on paper isn’t just old-fashioned; it leaves businesses vulnerable. Outdated and/or multiple document versions floating around the office, coupled with inadequate oversight and control, sows confusion and heightens risk.
 
More and more ARM businesses are moving toward centralized cloud storage platforms such as SharePoint to ensure internal documents are valid, secure, and easy to use, all of which are key to making sure policies and procedures are appropriate and effective. SharePoint offers version controls, prevents unauthorized changes, and allows employees instant access.
 
Once policies and procedures are reviewed and approved by compliance, they can be uploaded to SharePoint for all employees to view and search by keyword. Changes can be made from across the organization, and compliance is notified in real time so they can review the changes right away. All changes are documented for easy reference.
 
To train your team on SharePoint, check out LinkedIn Learning (formerly Lynda.com), which offers outstanding SharePoint tutorials.
 
 
 

3. Have a Formal System in Place for Reporting and Addressing Issues

In an ideal collections environment, nonconformities can be reported through multiple channels—directly to management, directly to compliance, or even through an anonymous voice portal. If you give employees multiple options, you’ll have more opportunities to research and respond to problems as they occur and to better protect your business.
 
If the issue being reported is a one-off occurrence requiring individual remediation, coaching and training should be specific and timely. It’s important to document your response; if the same individual makes the same error repeatedly, termination may be in order.
 
If the nonconformity is more widespread, you should make remediation via formal group training your top priority. Otherwise, you could see an avalanche of new infractions.
 
Remediation of compliance risk should be a closed-loop process that’s thoroughly documented and reported to your agency’s highest governing body. You can track all remediations by client and save audits and client Master Service Agreements (MSA) through SharePoint’s vendor management program.
 
Finally, you’ll need to evaluate corrective action on a regular basis. If an action isn’t getting results, make any necessary adjustments in accordance with current employment law.
 
 
 

4. Equip Your Team to Manage Compliance Effectively

Managing risk on the front line is easiest and most effective when it’s enabled by a robust, fully integrated compliance management system (CMS) with automated auditing and monitoring controls.
 
If you’re a smaller agency without a CMS in place, the CFPB website outlines everything the bureau might look for in your organization and what your CMS must include.
 
Here’s how tech-empowered ARM agencies manage risk with ease:
 
  • The board and director provide continual oversight, review assessment and risk review findings, and revisit policies and procedures on a regular basis.
  • Collectors receive timely feedback on their calls.
  • Operations leaders are instantly notified of exceptions related to call frequency limitations, allowable call times, calls made to cell phones without express consent, etc., with speech analytics helping to identify other types of nonconformities.
  • Complaint management and dispute tracking occur automatically.
  • IT teams are notified of systemic nonconformities and readily respond with any necessary changes.
When all these parts work together as a whole on a daily basis, fewer infractions go unnoticed. Potential problems are more easily prevented. A culture of compliance takes root, and a more compliant, efficient, profitable collections operation naturally results.

 

 

Disclaimer: Ontario Systems is a technology company and provides this blog article solely for general informational and marketing purposes. You should not rely on the content of this material for any other purpose or as specific guidance for your company. Ontario Systems’ advice, services, tools and products described herein do not guarantee compliance with any law or industry standard. You are ultimately responsible for your own company’s actions and compliance efforts. Because everyone’s situation is different, you must consult your own attorneys, accountants, and/or other advisors to obtain specific advice on your company’s compliance, legal, tax, regulatory and/or other business needs. Despite Ontario Systems’ efforts to provide current and up-to-date information, you need to recognize that the information contained herein may become outdated quickly and may contain errors and/or other inaccuracies.

© 2019 Ontario Systems, LLC. All rights reserved. Information contained in this document is subject to change. Reproduction of this publication is not permitted without the express permission of Ontario Systems, LLC.

How Do Consumers View the CFPB's Proposed Rules?

Consumer advocates and the credit and collection industry are at opposing ends of the spectrum when assessing the CFPB’s proposed debt collection rule. But now, the industry can hear one of the leading consumer advocates share her perspectives.

In a recent webinar, hosted by AccountsRecovery.net, Margot Saunders, senior counsel at the National Consumer Law Center, and Rozanne Andersen, VP and chief compliance officer at Ontario Systems, discuss the CFPB’s proposed debt collection rule from opposite sides of the issue.

A Challenge for ARM Leaders: Finding Opportunities in the Chaos

A Challenge for ARM Leaders: Finding Opportunities in the Chaos

Since President Trump declared a national emergency due to COVID-19, ARM leaders across the country have been forced into a minefield of swift decisions to continue operating, meet client requirements, and stay compliant with state restrictions. The last...