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.
What do you do when a client creates compliance risks for your organization? This is a common issue that happens throughout the industry especially when you are working with non-bank creditors that are not as closely tied to consumer financial laws.
During this week’s Research Assistant Peer Call one of our members expressed their frustration with client issues such as; double placed accounts, and responding to a consumer dispute with the client’s validation documents confirming the balance and then learning that the consumer received an actual paid in full letter from the creditor.
These issues are frustrating, time-consuming and create risk for debt collectors. Here are some of the practices that may help you when these issues arise:
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Implement a client education program – This may sound strange but I have personally experienced the positive impact this type of program can have. You can create a monthly compliance newsletter, establish regular client compliance training, or lead compliance meetings with your clients. The trick to making this program successful is to ensure you have the right people engaged. Make this about the clients success in recovering their past due receivables as much as it is about your need to comply with federal and state laws and regulations.
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Invoke your indemnification rights – This may sound obvious, but having a formal template notification ready to put clients on alert of their need to indemnify and hold you harmless for errors caused by them can often lead to client process changes.
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Terminate clients that cause high risk to your organization – In today’s regulatory environment we don’t have the luxury to turn our heads the other way when clients create undue risk to our organizations. In fact, the Consumer Financial Protection Bureau expects that we identify potential Unfair, Deceptive, and Abusive Acts and Practices risks in our clients processes. Regardless of how many accounts a specific client may represent for your company, it’s not worth the risk exposure and costs associated with clients that are not willing to work with you.
Documents and Crowdsourced Materials:
Top Reads:
Upcoming Webinars/ Other Announcements:
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Going to ACA’s Annual Convention Next Week? Join us for our RA meet-up at Kitty O’Sheas July 26, 2023 at 3:30 CT!
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TCN breaks down the need-to-know changes to the TCPA in their webinar, Open the Door to SMS for Debt Collection.
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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!
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