In 2012, insideARM submitted a FOIA (Freedom of Information Act) request to the FTC, asking for complaint data against the collection industry. In part, the goal was to see what made up the complaints — 199,721 in 2012; 180,928 in 2011 — since the collection industry is often dinged in the press for its complaints numbers: usually the second highest category each year in the FTC’s complaints report.
Upon close examination of the reports, however, what insideARM discovered is that a significant percentage of those complaints… weren’t. Or, rather: a consumer complained; however, the complaint, though attributed to a collection agency, may have instead been with the original creditor. Or the complaint may be been with the product purchased, but the complaint was lodged against the collection agency because that’s who happened to call.
Since the FTC doesn’t verify the complaints that come in for accuracy, non-complaints get mixed in with legitimate complaints and we end up with those earlier couple-hundred-thousand data points. Arguments about the professionalism of the collection industry are made and based off data that, while not rife with error, isn’t 100 percent verified and doesn’t tell the whole story.
We here at Persolvo were very interested in the process insideARM used, and the conclusions it reached in its investigation into the FTC’s complaints data. The debt settlement industry finds itself in similar waters. Historically, the debt settlement industry has enjoyed a less than stellar reputation in the eyes of most ARM professionals. While that’s softening a little (see our two whitepapers: “Debt Settlement Survey: How Creditors and Collectors Increase Collections” and “Debt Settlement Survey Round II: How Creditors and Collectors Increase Collections“), in our most recent suvey of ARM professionals, over 30 percent of those who do not use a debt settlement company as part of their complement of services said it was due to “legal concerns (FDCPA) about dealing with third parties.”
So we asked insideARM to submit a FOIA request that looked at consumer complaints against the debt settlement industry. The next several blog posts will share our findings, opinions, conclusions, and suggestions. We’ll also look in some detail at the ways in which the ARM industry is and isn’t utilizing the debt settlement industry.