Archives for December 2019

On December 10, 2019, the Consumer Financial Protection Bureau’s (CFPB) Director Kathleen Kraninger spoke at the National Association of Attorney Generals Captial Forum. In her remarks, Kraninger referenced the CFPB’s rulemaking in debt collection and offered a view of the near future: a Supplemental Notice of Proposed Rulemaking (SNPRM) for time-barred debt disclosures is coming “very early in 2020.” 

Kraninger mentioned that the CFPB’s testing of these disclosures is completed. The survey was first announced in February 2019. For guidance on time-barred debt disclosures, Kraninger states that the CFPB looked to relevant state laws and enforcement actions. The Director mentions:

These disclosures are inextricably linked to state law. Reconciling these disclosures could help consumers receive the benefits of federal and state disclosures, while at the same time reducing uncertainty and compliance burdens for debt collectors.  

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insideARM Perspective

There were enough hints that a supplemental NPRM for time-barred debt disclosures was coming, so this news is not too surprising. Other than the consumer survey, the most obvious hint was the big ol’ placeholder in the statute of limitations/time-barred debt section of the proposed rules.

As with the NPRM, we can expect the SNPRM to have a comment period once it is published in the Federal Register, so those in the industry who have input on this matter should ready themselves to prepare and submit a response. Time-barred debts are sensitive, and industry members who regularly interact with consumers on this type of debt have unique insights that should be shared with the CFPB, e.g., how real consumers react to these disclosures in-market versus through a controlled survey.

On December 10, 2019, the Consumer Financial Protection Bureau’s (CFPB) Director Kathleen Kraninger spoke at the National Association of Attorney Generals Captial Forum. In her remarks, Kraninger referenced the CFPB’s rulemaking in debt collection and offered a view of the near future: a Supplemental Notice of Proposed Rulemaking (SNPRM) for time-barred debt disclosures is coming “very early in 2020.” 

Kraninger mentioned that the CFPB’s testing of these disclosures is completed. The survey was first announced in February 2019. For guidance on time-barred debt disclosures, Kraninger states that the CFPB looked to relevant state laws and enforcement actions. The Director mentions:

These disclosures are inextricably linked to state law. Reconciling these disclosures could help consumers receive the benefits of federal and state disclosures, while at the same time reducing uncertainty and compliance burdens for debt collectors.  

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insideARM Perspective

There were enough hints that a supplemental NPRM for time-barred debt disclosures was coming, so this news is not too surprising. Other than the consumer survey, the most obvious hint was the big ol’ placeholder in the statute of limitations/time-barred debt section of the proposed rules.

As with the NPRM, we can expect the SNPRM to have a comment period once it is published in the Federal Register, so those in the industry who have input on this matter should ready themselves to prepare and submit a response. Time-barred debts are sensitive, and industry members who regularly interact with consumers on this type of debt have unique insights that should be shared with the CFPB, e.g., how real consumers react to these disclosures in-market versus through a controlled survey.

ATLANTA, Ga. — On November 21, 2019, Tracie Hazelwood, Client Accounts and Solutions Manager for First Financial Asset Management, or FFAM360, participated in Covenant House Georgia’s Sleep Out to support homeless youth in Atlanta, Ga. 

The Sleep Out Movement takes place across the United States and Canada as an act of solidarity to show homeless youth unconditional love and absolute respect. Participants are challenged to sleep outside for one night at a Covenant House site, private backyards, school grounds, and safe community spaces. Sleep Out participants use a piece of cardboard and a sleeping bag to sleep outside in a safe location. Through Sleep Out, participants become advocates for homeless youth and raise funds for Covenant House.

It is estimated that 4.2 million youth experience homelessness each year. Of those 4.2 million, some 700,000 youth are unaccompanied, or without a parent or guardian. Chapin Hall at the University of Chicago conducted an extensive examination of homeless youth called the Voices of Youth Count and found that approximately one in 30 youth aged 13-17 will experience some form of unaccompanied homelessness in a year. On any given night, there are around 41,000 unaccompanied youth homeless and sleeping on the streets in the United States.

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Covenant House Introduction

Active in many community organizations, Ms. Hazelwood was introduced to Covenant House in 2018 through an industry colleague. She immediately became an active supporter through a food donation at Christmastime. As a result of discussions with her colleague at various conferences throughout the year, Ms. Hazelwood made the commitment to participate in the Sleep Out Movement. 

Sleep Out Experience

On the evening of the November 21st Sleep Out, Ms. Hazelwood and the other participants joined Covenant House youth in a candlelit vigil. During the vigil, the name of each youth who returned to the streets or didn’t make it was spoken aloud in a time of remembrance. After the somber vigil, Sleep Out participants and Covenant House youth shared a meal together, exchanged stories, and took a tour of the Covenant House Georgia facility. Before it was time to sleep, the youth performed a variety show, showcasing each child’s talent. At bedtime, the noises of the city made for a restless night which is typical for children living on the streets. 

Covenant House Georgia

In 2019, Covenant House Georgia served more than 1000 of the 3,300 homeless youths in the Atlanta, GA area. Providing safe shelter, clothes, food, medical exams, and more, Covenant House Georgia provides services and safety for children to reach their fullest potential— finishing high school, starting college, gaining employment, living independently, and ultimately stepping out into the world to find success. 

Get Involved

Ms. Hazelwood is raising funds for Covenant House through December 31, 2019. If you would like to donate, please visit Tracie Hazelwood’s Donation Page. For more information on Covenant House, please visit covenanthouse.org.

About Covenant House

Covenant House is a nonprofit 501(c)(3) organization that provides a continuum of care for homeless children. For over 40 years, Covenant House has provided educational programs, job training and placement, medical services, mental health and substance abuse counseling, legal aid and beyond, to help young people embrace the great promise of their lives, overcome steep barriers to independence, and strive to achieve their aspirations. Covenant House shelters and cares for homeless and trafficked youth in 31 cities across 6 countries. 

About FFAM360

The FFAM360 group of companies deploys world-class people, operations, and technology to deliver revenue cycle solutions to their clients that optimize their credit and revenue lifecycles. Founded in 2002 with the vision of creating a best-in-class organization that provides comprehensive solutions across the Insurance Subrogation, Healthcare, Staffing, and Financial Service sectors, FFAM360 has achieved many significant awards and recognitions including being honored by the Women’s Business Enterprise National Council (“WBENC”) as a Certified Women-Owned Business Enterprise. FFAM360 is headquartered just outside Atlanta, GA with additional offices in Phoenix, AZ and Paso Robles, CA.

GENESEO, N.Y. — Coast Professional, Inc. (Coast) recently promoted Brooke Singletary to Vice President of Business Development. Brooke’s promotion is a direct result of her unmatched work ethic and exemplary success, as well as her dedication to upholding Coast’s core values. 

Brooke began her career at Coast in 2012 as the Marketing Coordinator, and was quickly promoted to the Director of Sales and Marketing. In 2018 she was promoted to Senior Director of Business Development. As Vice President, Brooke oversees the Marketing and Sales departments and will continue to be instrumental in achieving the company’s client growth and sales targets. Over the course of her tenure with Coast, she has contributed to the implementation of new business lines and the onboarding of new clients. In 2019, Brooke led the company’s sales team to a 27 percent sales growth and has increased the company’s client base by 95 percent since starting with Coast.

 “Brooke’s ability to get things done, coupled with her exemplary leadership skills, makes her one of the most dynamic sales and marketing leaders in the business,” said Jonathan Prince, Coast COO. “The work she has done over the last 12 months speaks volumes about her drive and interpersonal skills. Brooke’s outreach efforts have led to the implementation of important company milestones. I want to personally congratulate Brooke on her well-deserved promotion.” 

A resident of Hahira, Ga. and mother of two children, Brooke is an active member in her church and community.

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About Coast Professional, Inc.

Coast Professional, Inc. is an accounts receivable management company, dedicated to the respectful and ethical collection of higher education and government debt. Coast provides professional collection services to over 200 campus based colleges, universities, and government clients. Coast is a six-time honoree on the Inc. 5000 list for American’s Fastest-Growing Private Companies provided by Inc. Magazine and in 2019, was recognized for the fourth time as one of the “Best Places to Work In Collections” by insideARM.com and Best Companies Group. Since 1976, Coast has worked closely with clients to increase recoveries by assisting consumers in resolving their financial obligations. Coast’s success is exemplified by exceptional recoveries, superior service, and dedication to the highest levels of compliance. More information about Coast can be found at www.coastprofessional.com

As part of its ongoing commitment to community outreach and giving, Summit A•R, a collection agency in Minnesota participated in the Toy Shoppe program offered by Cross Food Shelf this year at Christmas. The staff and their families donated money and time handing out toys and stockings for children who would otherwise have no Christmas. “Our employees and their families never fail to impress me with their generosity and heartfelt compassion for the people in this community”, said Tim Turner, President of Summit A•R.

Toni Olson, Director at Cross Food Shelf had this to say: “Our staff was overwhelmed by Summit A•R ’s goodwill and kindheartedness. We are grateful to have people in our community who are such a blessing to Cross.”

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About Summit A•R 

Founded in 1996, Summit A•R  (Summit Account Resolution) is a national revenue cycle management company serving health care, commercial, consumer and many other industry segments in various stages of the revenue cycle. Their focus is to “Preserve Human Dignity” with their P.H.D. collection philosophy. They are members of the ACA, IACC, AAHAM, and BBB among other local and national organizations.  888.222.0793 or www.SummitCollects.com

Now in its thirteenth year, insideARM.com’s Best Places to Work in Collections program recognizes the most positive workplace environments in our industry.  I will be so bold as to say that every collection agency, law firm, or debt buyer with 15 or more employees must absolutely participate. By the way, participation is free.

We do not host this program because it’s a moneymaker for us. It isn’t. We host it because it’s good for the industry, and it offers participating companies essential data, gathered confidentially, about what their employees really think. You simply can’t get this information any other way.

I am constantly told that one of the biggest barriers to profitability in this industry is employee turnover. If your staff is unhappy, do you think they are as productive as they could be, or that they are representing you and your clients as they should be? Of course not. But where to begin to address employee satisfaction? Your Best Places to Work in Collections results provide you with a roadmap. Please, take advantage of this great opportunity.  

Register your company now.

Compete against companies of your own size.  No need to feel that you can’t measure up against the benefits and resources of a large company, or the family feeling of a small company.  Rankings are determined within three size categories, are: small (15-49 employees), medium (50-149 employees) and large (150+ employees).

Winners have enjoyed great benefits including enhanced reputation with creditors, morale boost, and recruiting support.

It works like this:

1. Employers complete a questionnaire on workplace policies, practices, philosophy, systems, benefits, and demographics. It can take about 4-8 hours to gather all of the info for this questionnaire – but hey, if it was totally simple, it wouldn’t produce meaningful results – and if you register now, you’ll have several months to pull it together. (You don’t have to do this part until February. Right now, all you have to do is register your company, which takes about 60 seconds.)
2. Employees are asked an in-depth set of questions — you choose online or via paper format; either way it takes the typical employee about 10-15 minutes to complete.

That’s it. Within about 6-8 weeks of completion, our partner, Best Companies Group, will produce a list of winners and we start to make announcements.

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The process is confidential.  insideARM does not have access to any employee responses. Best Companies Group, which collects all data, evaluates, and selects winners, has no connection to the debt collection industry.  If your staff is — ahem — less than kind, nobody will know but you.  But YOU should know!

Participating companies will receive a free Employer Benchmark Summary which reveals averages on standard employee benefits and best practices reported by those that made the list and those that did not. This is a great tool to help benchmark some of the most common benefits offered compared to those of your organization.

Participants will have the opportunity to purchase the full Employee Feedback Report that provides valuable data including a spreadsheet summarizing employee feedback and written employee comments, as well as a 30-minute consultation call with a Best Companies Group survey specialist.

These reports offer incredibly valuable information at an unbelievably fair price, regardless of whether you are selected as a winner.  The value in having a 3rd party conduct this survey is that you get candid information from your employees; your HR department could never gather this type of information.  And if you chose to do it independently, you’d pay $5,000-10,000.

Simply participating will show your employees that you care, which is critical to retention.  Winning gives you bragging rights and an invaluable recruiting tool.

Learn more about the program, or register here.

Representative Maxine Waters (D-CA), who is the Chairwoman of the House Financial Services Committee, has often criticized the actions of the Consumer Financial Protection Bureau (CFPB) since the appointments of Director Kathleen Kraninger and Former Acting Director Mick Mulvaney. Chairwoman Waters has frequently raised the issue of the increasing number of political appointees at the CFPB—most vocally against Eric Blankenstein, who allegedly overruling CFPB staff recommendations in regards to settlements with financial services companies to the detriment of consumers and previously made controversial remarks on his blog. 

Now, Chairwoman Waters expresses her concerns about a new political appointee who seems to be headed to the CFPB. Thomas G. Ward is allegedly the current front runner for the position of Enforcement Director. Yesterday, Chairwoman Waters sent a letter of concern to Director Kraninger for allegedly politicizing the CFPB. The letter discusses guidance from the Office of Personnel Management (OPM) to not give preference or special advantage to political appointees, and that federal agencies must seek OPM approval prior to appointing a political appointee to a permanent position.

The letter warns:

The potential selection of Mr. Ward for Enforcement Director raises serious concerns about whether the Consumer Bureau has adhered to civil service laws and OPM guidance governing the hiring of political appointees into career positions. 

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The letter requests that Director Kraninger and the CFPB provide information and records for review by the House Financial Services Committee. This review is part of the Committee’s oversight duties over the CFPB, including to “ensure that personnel actions in the civil service remain free from improper political influence.” The requests for information ask for communications between the CFPB, OPM, and the Department of Justice—where Ward is currently employed—as well as communications between the CFPB and Ward regarding the Enforcement Director position.

NEWARK, Del. — SIMM Associates employees participated in a Holiday Food Drive that benefited the local Newark branch of the Food Bank of Delaware. The total weight of the non-perishable food came to 714 pounds! These types of food drives are very important to the local food bank’s ability to provide food to the thousands of individuals they serve.  

“I’m very proud of our employees and all they do for our local community,” said Co-Founder and Chief Operating Officer Jeff Simendinger. “There was no need to encourage our staff to donate, once the idea was hatched everyone gathered together to donate what they could. Donations and kind deeds during the holidays can make a huge difference in the lives of those in need and our employees definitely answered the call.”  

The Food Bank of Delaware is a nonprofit organization dedicated to feeding Delawareans in need. 

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About SIMM Associates, Inc. 

SIMM is a full service nationally licensed ARM company providing collection solutions to the student lending, consumer lending, credit/retail card, healthcare, auto finance, credit union and debt buying industries. SIMM provides best in class deceased care solutions that encompass decedent verification, estate location scrub, proprietary Probate Tracker SM claim filing process and an empathetic survivor recovery solution all performed with brand sensitivity and regulatory compliance in mind. SIMM has passed the US Department of Education’s stringent requirements and currently is a subcontractor for the existing Private Collection Agency contract. Its headquarters is located in Delaware in a 32,000 sq. ft. state of the art call center. SIMM holds the following certifications: PCI Level 1, ISO 27002 and SSAE16 Type II. SIMM services customers throughout the United States including Puerto Rico. 

For more information please contact Jeffrey Simendinger, COO, jeff@simmassociates.com, (302) 2832802.

LAWRENCE, Mass. — Valentine & Kebartas, LLC (V&K), based in Lawrence, MA, today announced it achieved Historically Underutilized Business Zone (HUBZone) recertification through the U.S. Small Business Administration (SBA). The HUBZone program helps small businesses in urban and rural communities gain preferential access to Federal procurement opportunities. The program was enacted into law as part of the Small Business Reauthorization Act of 1997.

V&K has decades of service to student loan creditors, including current service to one of the largest and best-known guaranty agencies in the higher education sector.  Operational and regulatory requirements of collection agencies working for guarantors are highly comparable to those on Federal contracts like the U.S. Department of Education (ED) Private Collection Agency (PCA) contracts, the largest single Federal client for collection agencies.

V&K is one of thirty-one (31) HUBZone-certified small businesses listed at www.sam.gov under the NAICS code for debt collection (561440) with the capacity to collect Federal student loans and act as a contact center to communicate with borrowers.

V&K management offers decades of experience in the industry, with strong emphasis on operations and compliance. The close-knit management team believes personal connections are key to leveraging its talented and knowledgeable agents to ensure top performance and results. 

Among other requirements, the Federal HUBZone program requires a firm’s principal office to be located within a Federal HUBZone, with no less than 35% of all employees residing in HUBZones.  V&K obtained the recertification to compete for opportunities to work as a subcontractor to PCAs.

Chief Operating Officer Scott Sweeney stated, “Our goal as a Certified HUBZone small business concern is to offer an experienced staff with a proven track record of delivering top performance and compliance to not only help clients meet their socio-economic quotas, but to enhance their results as a whole.”

V&K is a member of the Fed Cetera Network, an organization comprising dozens of pre-qualified companies PCAs can hire to meet subcontracting goals, including those in all specially-designated socioeconomic groups. “With most of the HUBZone-certified small business collection agencies among our members, it’s never been easier for PCAs to access so many highly-qualified HUBZone small businesses like V&K with a single phone call,” said Leah Wilson Conger of the Fed Cetera Network. “We will be responsive to PCA outreach in this important area.”

About V&K

V&K is a HUBZone-certified, privately-held national collection agency with its office located in Lawrence, Massachusetts. V&K handles outsourcing, primary, secondary and legal placements for a wide array of clients and for different receivables needs.  The firm employs roughly 150 representatives, with a majority of the business dedicated to higher education. The management team has an average of 22 years of industry experience. V&K is licensed and bonded to perform collection activities nationally. By building long-term relationships with their clients and providing excellent results, V&K provides security and peace of mind to their clients.

This article is part of an ongoing Think Differently series, launched in October 2019. Written by members of the iA Innovation Council, the series showcases thought leadership in analytics, communications, payments, and compliance technology for the accounts receivable management industry.

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Today marks the almost-anniversary of my first article on insideARM (published 12/18/18), The ARM Industry’s Major Problem; Undervaluing Invaluable Technology, in which I declared, “Your company doesn’t value today’s technology.” When the Innovation Council’s Think Differently series was recently announced, I knew I wanted to mark the anniversary of my initial article by looking back at the progress made since that declaration.          

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Let’s take inventory as we close out the year and plan for 2020.

While technological advancement has been relatively slow—albeit a point of curiosity—the CFPB’s proposed rule released in May of this year kicked the conversation into overdrive. Fast-forward to September and the Consumer Relations Consortium announced plans to split into two groups: the CRC (the compliance/regulatory group) and the Innovation Council (the tech/strategy/ops group), and insideARM announced a new conference, iA Strategy & Tech. Other industry organizations also began to incorporate technology into their agendas.

With the buzz about “digital this,” “tech that,” artificial intelligence, machine learning, and omni-multi-every-channel communication, how did your plans for digital transformation go? If you are looking down at your feet, you’re not alone. 89% of all companies want to be “digital-first” but a reported 70% of digital transformations fail. This means we, as an industry, need to come together and find out why before we address the how (or you can just click that last link and learn from McKinsey & Co).

Here are some points of resistance I’ve heard from peers across the credit and collections industry:

• Lack of communication – If you’re not communicating across the entire organization that your company is implementing new technology and encouraging everyone to embrace it, you will encounter employee resistance. Your Chief Technology Officer won’t lead you into digital transformation alone and if he or she is left to make all decisions. For instance, someone in accounting (or insert any other department) will feel the stress of unannounced change affecting their normal workflow.

• Lack of vendor/partner engagement – 80% of companies say that digital transformation involves multiple units across the business. We now operate in a real-time world with IoT (Internet of Things) and “apps” that offer instant connection. Enterprise B2B solutions aren’t as simple as downloading an app from an app store, so communication with vendors and partners is critical to success. Yet I’ve heard that some vendors are resistant to working with competitors because they think they can do everything, and some customers are resistant to introduce vendors who could partner to deliver better service because they think this may lead to higher cost.

• Lack of vision and goals – Companies want to text; they want to email; they want to contact more; they want to contact less… you get the point. The obvious goal is to increase revenue, at a lower cost, and to do so compliantly. Yet I’ve observed a lack of coordinated vision in many organizations. My advice is that you take it to the drawing board. Gather all department heads, get input from everyone, agree on a strategy, and then spread it repeatedly through the organization to get employee involvement. Define the vision. Then empower a champion to make sure it happens.

What’s the payoff for transforming your collection strategy and becoming a digital-first organization? Learn about it here: the free Digitizing Your Collections webinar from insideARM’s ARM-U series. Frederic Jacques of McKinsey & Co. and I served on the panel, and we show you the value of a true digital collection strategy.

Start looking internally, at your people, and get the discussion going so that 2020 is the year you take action. Planning starts now.

The article I wrote one year ago remains just as relevant going into 2020. Adopting new technology should be your #1 initiative – even if that means making uncomfortable changes.

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Josh Allen is the founder and CEO of Revenly, a digital-first, consumer-focused platform that meets the demands of today’s payer, and a member of the iA Innovation Council.

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About the iA Innovation Council

The iA Innovation Council is a collaborative working group of product, tech, strategy, and operations thought leaders at the forefront of analytics, communications, payments, and compliance technology. Group members meet in person several times each year to engage in substantive dialogue and whiteboard sessions with the creative thinkers behind the latest innovations for the industry, the regulators who audit and establish guardrails for new technology, and educators, entrepreneurs and innovators from outside the industry who inspire different thinking. 

Learn more at www.iainnovationcouncil.com

2019 members include: