Welcome to the Research Assistant Weekly Newsletter - a subscriber-only resource for insight into emerging compliance challenges, details on peer calls, and links to new Research Assistant reports, documents, tools, and more.

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During this week’s Research Assistant peer group call, we had an in-depth discussion regarding corrective or disciplinary actions that have reversed poor collector behavior. Here are a few of the highlights: 

• Tone from the top. The overwhelming consensus was that without Executive Leadership’s support it is extremely difficult to change collector behavior. Even with bonus deductions or other punitive measures, the tone from the top ultimately impacts the compliance culture within an organization. 

• Progressive Discipline. Another key element is making sure you are strictly following a progressive disciplinary policy within your organization. If your progressive disciplinary policy is effective then you shouldn’t have repeat offenders. 

• Communication and Transparency Make sure you are communicating compliance expectations, and the reasons behind them to senior operations people regularly. Operations’ role is to understand compliance expectations and enforce them but they do not always fully appreciate the magnitude of compliance risks associated with the requirements. Keeping the lines of communication open between Compliance and Operations is critical from a messaging standpoint. 

During our discussion, many people on the call shared stories about how they overcame these roadblocks. Providing Executive Leadership with data-driven metrics was the biggest driver in changing the tone about using monitoring results for disciplinary action. Litigation costs and settlements are one of the most concrete ways to show how non-compliant behavior impacts the bottom line. Reporting on those trends regularly will only help your case. CFPB enforcement actions can help you paint a similar picture. Ultimately though, organizations must remove bad actors from their offices or it’ll be an uphill battle to effectively change the culture.

Documents and Crowdsourced Materials:

• Escheatment Policy Template

• Deceased Policy Template

Top Reads: 

• CFPB Critical of Deleting Tradelines

• California DFPI Proposes Extensive Rules Relating to Companies’ Responses to Consumer Complaints

• CFPB Focuses on Innovation; Creates New Office and Hints at Future Rulemaking

Upcoming Webinars/ Other Announcements:

• Reminder: Send any topics or questions that you want to discuss to sara@insidearm.com by Thursday to ensure it makes it on our agenda!