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.
In this week’s Research Assistant Peer Group call we discussed an article that said there is an upward trend in debt collectors ignoring cease communication requests. The peer group generally didn’t agree with this trend analysis, but we did have a good discussion about keeping up with training to ensure cease communication requests are not confused with inconvenient or unusual time or place.
And then the shoe dropped…
One of our members informed us that they recently identified that credit repair organizations (CRO)’s have been flooding them with email cease communication (and dispute) notices. This is to be expected but what they did not anticipate was that the CRO would be creating dummy email addresses to send the notices, causing the data security controls to block the emails from being delivered to the collection agency.
That left us wondering, what’s the best way to handle this issue? Here are a few thoughts, albeit not inclusive of all possible solutions.
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First, identify if you are experiencing these issues by collaborating with your information technology and security team to see if emails are being blocked from potential CRO’s.
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Watch your complaint trends for allegations of multiple requests for cease, dispute, etc requests but you have no record of it and add a review of blocked emails to your investigation.
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Remove your company general email from letters, websites, etc. instead send consumers to a hyperlinked form.
Regardless of how you decide to address this issue, it’s important that at a minimum you educate your team that this is something that needs to be monitored and evaluated for risk to reduce your risk of lawsuits.
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