Mike Bevel is an Editor for insideARM.com. You can follow him on Twitter: @MikeBevel_iA. You can also email him about Charles Dickens, Shannen Doherty, Angela Lansbury, and "Murder, She Wrote." He lives, laughs, and loves in Rockville, Maryland. He is terrified of whales.
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On July 18, 2015 the FCC published a declaratory ruling in response to questions from the telecommunications, telemarketing, and receivables management industries. This ruling was intended to provide direction and clarity around the definition and use of technology used in contacting consumers; however, many felt this ruling in fact muddied the waters further. What follows […]
The debt industry has a story, but it is one told about it, rather than by it, generally. And, according to a crisis management consultant, that’s the wrong way for the industry’s stories to be told. Consumer media outlets — your Wall Street Journals; your nightly news segments; your Times, both Financial and New York […]
The Colorado Department of Regulatory Agencies is performing a “sunset review” of Colorado’s Fair Debt Collection Practices Act. The Colorado General Assembly sets specific dates that a particular agency, board, or, in this case, function of government will terminate unless the legislature passes new legislation to continue. A sunset review will generally question the need for regulation […]
The Three Lines of Defense, in a highly regulated industry such as the debt indsutry, has become a must and a norm. Regulatory bodies such as the CFPB, the FTC, and the OCC are all expecting to see this type of framework in this industry.
Two attorneys — one for collections, one for consumers — talk through urgency channels, convenience fees, and due dates. It’s another example of how language that, on the surface, seems helpful and clarifying for a collection agency, can also be seen as deceptive, by a consumer attorney, to the Least Sophisticated Consumer.
Are you currently putting the (e)11 disclosure on all communications, or are you being selective? How are you auditing to make sure the right disclosures go on the right letters, and how quickly can you fix it when things go wrong?
insideARM and The Compliance Professionals Forum are looking for compliance- and operations-themed presentations for their spring and fall semesters of ARM-U. ARM-U is a three-day series of webinars. Each presentation is 90 minutes, and two sessions happen each day. Spring Semester is March 22, 23, and 24 (with sessions from 2.00 p.m. – 3.30 p.m. Eastern; […]
In a 6-3 “no” for the industry, Ruth Bader Ginsberg, in her majority opinion, writes, “Campbell’s settlement bid and Rule 68 offer of judgment, once rejected, had no continuing efficacy. Absent Gomez’s acceptance, Campbell’s settlement offer remained only a proposal, binding neither Campbell nor Gomez. Having rejected Campbell’s settlement bid, and given Campbell’scontinuing denial of liability, Gomez gained no entitlement to the relief Campbell previously offered.”
Technology options like this were mentioned back in June, when the FCC held its mid-year TCPA clarification hearing. Several commissioners described the technology as a consumer-friendly way to escape the perceived constant pressure of intrusive calls. But is it possible this technology can do more harm for consumers and their financial health than good?
Policies and Procedures are here to stay and will become the heartbeat of your organization. Aside from all the elaborate ways of writing policies and understanding the right approach to use when developing procedures, one must first consider and understand how they will impact the health of your organization from a different angle.