While the effective date is currently uncertain (see CFPB Proposes to Delay Effective Date of Reg F for 60 Days), many agencies are still in the position of ensuring that the technology they're using also offers them access to many of the safe harbors provided.
In a recent survey of technology and the collections industry, Telrock, partnering with insideARM, wanted to see what risks and vulnerabilities agencies were facing. Two things became clear:
1) Nearly half of those surveyed were working on systems that were 10 years or older.
2) And almost all agencies (91%) planned to rely heavily on technology vendors to help with the technology requirements now necessary via Regulation F.
While some of those systems that are 10+ years old have been maintained with updates and patches, many are finding themselves in vulnerable positions. And nine months does not leave most collection operations with much time for set-up, testing, and refining by the November deadline. Collections operations could be scrambling to get the needed system capabilities in place in time and may miss the deadline.
So the heavy reliance on technology partners makes a lot of sense, and suggests the need for strong and vital collaborations between agencies and tech vendors to make sense of Reg F and its implementation. [article_ad]
If you find yourself in the position of wrangling a system over a decade old, it's vital that you start conversations with your technology vendors. Are you running on the latest version offered? And does the latest version fulfill the new requirements Reg F is introducing?
For more insights into the industry's use of technology, download Telrock's free whitepaper, System Capabilities & the New CFPB Rules.