Santa Clara County Selects CSS IMPACT Financial Debt Collections & Ai Digital Consumer Engagement Cloud

SANTA CLARA COUNTY, Calif. — The County of Santa Clara, known as “Silicon Valley,” the birthplace of the high technology revolution, selects CSS IMPACT Financial Debt Collections Cloud Ecosystem “HD 2.0 | COLLECTIONS” & “HD 2.0 | Ai” (Digital Consumer Engagement Artificial Intelligence Suite) as their “NextGen” Tax Information Collections Platform. CSS, Inc. is a leading provider of Next-Gen Debt Collections Ecosystems with a focus on “Ai” (Artificial Intelligence) machine learning Digital Collections. The HD 2.0 | Ai system, a “Digital First” collections & debtor engagement platform allows agencies to deploy agent-less servicing functions to negotiate, settle, make payment arrangements, receive payments & answer common questions passively & positively without changing the debtor behavior by using common IoT channels of communications, such as Google Assistant, Google Ai Voice (phone), Text, Chat, Online portals, as well as legacy channels such as Dialers, Click-to-dial mobile contacts, Text Messaging, IVRs, & emails.

Cities like San Francisco, Los Angeles, San Diego, and now the County of Santa Clara, are leveraging CSS’s Digital First Financial Ecosystem Collections & AI (Artificial Intelligence) self-servicing Cloud platforms to deliver centralized debt management and collection automation processes with along with a frictionless Digital Consumer Engagement experience efficiently streamlining and maximizing the County’s workforce resources, enabling them to focus on increasing revenue management strategies & delivering an even greater customer service.

The County of Santa Clara, better known as the Silicon Valley, is a major hub for world renowned technology companies. As such, it is not surprising that the County is a leader in innovation and digital transformation, continuously adopting cutting-edge digital tools to deliver operational service excellence to its citizens.

The County’s vision is to revolutionize modern governance by enabling smart, mobile, transparent, and engaging public services by the adoption of cloud technologies with smart AI-enabled services to drive increased constituent participation while building trust with its citizens.

This vision is defined in its Technology Services and Solutions (“TSS”) strategic plan mission statement: “Transforming the County services through collaboration, technology innovation, and operational excellence”.  The County’s selection of CSS IMPACT HD 2.0 | Collections Ecosystem as its platform of choice aligns with this vision of delivering services leveraging the latest digital technology to improve productivity and quality of service while enhancing citizen experience and engagement.

“The County of Santa Clara‘s selection of CSS, Inc. on June 30, 2020, provides the opportunity to improve upon our collection processes, and customer service delivery to the community. We look forward to implementing CSS IMPACT Ecosystems as the new revenue recovery solution for the County”, said Margaret Olaiya, Director of the Tax and Collections Department for Santa Clara County.

“All of us here at CSS are truly honored to have been selected by the County of Santa Clara for this implementation. The deployment of our “NextGen” HD 2.0 | Collections Ecosystem will now allow the county to consolidate and centralize disparate legacy systems into a a single cloud, empower its users to deploy streamlined automated processes and make services much more efficient, effective, and transparent, all while providing a rich digital customer service experience to better serve its citizens. We are very excited about this partnership and we look forward to a long-term relationship with the County” said Sergio Seplovich, Executive Projects Director at CSS.

To learn more about how municipalities are leveraging CSS’s Cloud Financial Ecosystem, please visit https://www.cssimpact.com/collections, download our brochure at http://brochure.cssimpact.com or view our AI video at aicollections.cssimpact.com

About the County of Santa Clara

The County of Santa Clara is located at the southern end of the San Francisco Bay and encompasses 1,312 square miles.

World-known as “the Silicon Valley”, the County of Santa Clara is a major employment hub in the technology sector providing more than a quarter of all jobs in the Bay Area with one of the highest median family incomes in the country. Home to a population of nearly 2 million from a wide diversity of cultures, backgrounds, and talents, the County continues to attract people from all over the world.

Santa Clara is the home to three major universities, Standford, Santa Clara and San Jose State as well as to many of the most innovative technology companies in the world such as Intel, Google, Sun Microsystems, Hitachi, SAP, Agilent, IBM, Apple and Cisco.

About CSS, Inc.

CSS is a leading provider of end-to-end cloud Financial Ecosystem platforms & Contact Center solutions with a focus on “Ai” (Artificial Intelligence) machine learning Digital Consumer Engagement for enterprises that generate & manage mass receivables, payments, recoveries & revenues. By delivering cognitive cloud Financial Ecosystems technology, CSS helps municipalities and enterprises improve and automate all their daily financial processes, consumer engagement & business process. For more information, download our brochure at http://brochure.cssimpact.com or visit us http://www.cssimpact.com or call 877.277.4621.

Santa Clara County Selects CSS IMPACT Financial Debt Collections & Ai Digital Consumer Engagement Cloud

http://www.insidearm.com/news/00046618-santa-clara-county-selects-css-impact-fin/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

Ceteris Portfolio Services, LLC Enhances Their Cash Effusion Solution to Help Organization More Proactively, Effectively Manage Their Delinquent, Defaulted Portfolios

Mount Laurel, New Jersey — Ceteris has enhanced our Cash Effusion solutions to help our clients proactively manage their delinquent and defaulted portfolios during unprecedented economic times.  The enhanced solutions offer our clients a multi-channel, non-voice opportunity to stay connected with their customers.  In addition to improving performance and reducing costs, Cash Effusion provides the following: 

  • Compliance crafted language that leverages the psychological impact of receiving third party communications
  • Low cost and effective strategy to manage deposit account and low balance delinquencies
  • Attended IVR to help resolve any customer concerns and maximize collections
  • Comprehensive reporting to transparently measure and assess effectiveness
  • Fixed-fee and contingency-based collections options 

Backed by an unwavering commitment to compliance and data security, blended with continued investments in industry-leading technology, Ceteris’ Cash Effusion solutions are changing the way organizations manage their delinquent portfolios. 

About Ceteris Portfolio Services, LLC 

Ceteris Portfolio Services (CPS) is a premiere nationwide ARM firm providing end-to-end accounts receivable management solutions to assist clients in managing their debt. CPS partners with clients by creating unique solutions to significantly reduce their operating costs enabling them to focus on their core lines of business while improving their revenue and profitability. By offering a variety of operational and financial solutions based on the asset class and/or industry, we can create predictable cash flows – even with unpredictable assets.  For more information please visit www.ceterisholdco.com/CPS.

Ceteris Portfolio Services, LLC Enhances Their Cash Effusion Solution to Help Organization More Proactively, Effectively Manage Their Delinquent, Defaulted Portfolios
http://www.insidearm.com/news/00046623-ceteris-portfolio-services-llc-enhances-t/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

Intelligent Contacts and Payscout Announce Strategic Partnership to Provide Financial Services Industry a Consumer-Focused End-To-End Payment Experience

PLANO, Tex. — Intelligent Contacts, a leading provider of Cloud Contact Center software and consumer-centric online payment solutions for the healthcare and accounts receivable industries, today announced a product integration partnership with Payscout, an award-winning global payment processing provider. Payscout supports over 3,000 global merchants across all merchant risk verticals and processes billions of dollars annually.

Although integration between Intelligent Contacts payment portals and Payscout’s processing gateway has been in place for several years, the formal partnership will further streamline the process of consolidating and reconciling electronic payments across all digital payment channels.

“We believe Payscout is the ideal technology partner for our rapidly-growing online consumer payment solutions,” says Jeff Mains, CEO of Intelligent Contacts. “Payscout has proven throughout our relationship that they share our commitment to client-focused innovation driven by a highly-engaged and personalized customer service experience.”

With consumers now predominantly preferring to pay their bills electronically, businesses are adding more ways for their customers to pay digitally. As a result, many companies now use multiple vendors or payment platforms to satisfy the growing consumer demand for convenience and self-service. The Intelligent Contacts and Payscout partnership will allow companies to see and manage all of their digital payment channels in one centralized gateway.

“As a global payment processor with a history of helping thousands of entrepreneurs across all merchant risk verticals, we see tremendous value in partnering with other technology leaders who share our vision and commitment,” said Manpreet Singh, Co-Founder and President of Payscout.

The partnership merges each company’s decades of experience serving the highly-specialized needs of their healthcare and ARM industry clients. Healthcare and debt servicing are two of the most heavily-regulated industries in the US, and Intelligent Contacts and Payscout each bring expertise navigating the special protections and compliance requirements when it comes to storing personal data or collecting payments.

“In today’s modern payment landscape, it’s critical that our customers can access credit card processing services and data through state-of-the-art, web-based platforms,” said Singh. “It’s also equally important to provide customers with the highly-trained expertise that can only come from companies with proven track records of success. We believe our partnership with Intelligent Contacts satisfies these market needs and provides our customers with a powerful and feature-rich payment solution.”

In addition to meeting Payment Card Industry Data Security Standards (PCI-DSS) standards, the healthcare industry has HIPAA requirements and debt collection strict rules enforced by the Fair Debt Collection Practices Act (FDCPA).

“Our healthcare and debt servicing clients need payment technology partners they can trust from start to finish,” says Mains. “With this partnership, they get the industry experience and expertise they need. From boarding a new merchant account through going live with their payment products, we want that process to be smooth and pain-free.”

The partnership announcement coincides with the launch of a fully-integrated “No-Cost,” or “Fee Free” processing engine within Intelligent Contacts’ payment portals. This feature allows 1st and 3rd-party debt servicing companies to legally reduce or eliminate the fees paid to banks and credit card companies when payments are made electronically.

About Intelligent Contacts

Intelligent Contacts offers omnichannel communication and payment Software-as-a-Service (SaaS) applications for BPO, healthcare, financial services, government, and educational institutions. Its’ Intelligent cloud contact center software provides enterprise-level inbound and outbound call center functionality that includes skills-based call routing, payment IVRs, a TCPA-compliant auto dialer with predictive and power dialing modes, as well as call recording and voice analytics. 

Intelligent Portal is an online payment portal that allows consumers to see and manage their bills or delinquent unpaid balances, select or create their own payment plan, or virtually negotiate a final payment to settle their account.

To learn more about Intelligent Contacts, visit https://intelligentcontacts.com/, or follow us on Twitter and LinkedIn.

About Payscout LLC

Payscout is a global payment technology company with acquiring solutions in the United States, Canada, China, Brazil, and the European Union. Payscout’s Paywire Ecosystem offers integrated payment processing solutions focused on vertical-specific industries such as Accounts Receivable Management, Heathcare, Education, and Enterprise merchants with a global presence and complex requirements. Payscout has earned acclaim as a new-generation provider of merchant banking services, specializing in online/ecommerce solutions with a predominant proportion of card-not-present (CNP) transactions.

For more information visit https://www.payscout.com.

Intelligent Contacts and Payscout Announce Strategic Partnership to Provide Financial Services Industry a Consumer-Focused End-To-End Payment Experience
http://www.insidearm.com/news/00046619-intelligent-contacts-and-payscout-announc/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

A WCCF Video Interview Series: Five-in-Five. Amy Perkins Speaks with Le’Nore Caldwell

Women in Consumer & Commercial Finance is all about connection. For #fiveinfive, WCCF Chair Amy Perkins connects with sharp women from across financial services for short, intimate conversations about careers, confidence, building a mighty network, helping others and more. Check out the videos and get connected through WCCF! Registration is now open for WCCF Digital – December 8-10, from your home, desk, or anywhere you choose to be. Sign up today!

—-

Le’Nore Caldwell, Sr. Manager of Vendor Oversight at InvestiNet, LLC

Some people I meet, make me incredibly remorseful that I didn’t meet them sooner. Today’s guest, Le’nore Caldwell, is one of those people. Take a listen and you’ll see why! I have a feeling nothing is going to stop her.

 

[article_ad]

A WCCF Video Interview Series: Five-in-Five. Amy Perkins Speaks with Le’Nore Caldwell

http://www.insidearm.com/news/00046615-wccf-video-interview-series-five-five-amy/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

It’s Time to Think Differently About the Possibilities of Text Communication

This article, written by insideARM’s CEO Stephanie Eidelman, is part of the iA Think Differently series. Written by or recorded with members of the iA Innovation Council, the series of articles and videos showcases thought leadership in analytics, communications, payments, and compliance technology for the accounts receivable management industry.

Are you familiar with the term, Rich Communication Services (RCS)? It’s possible that you are but may not realize it. RCS is the communication platform that is likely to replace SMS text messages. And I predict it will revolutionize the way collectors communicate with many consumers.

[article_ad]

We engaged in an RCS brainstorm session at the recent summer meeting of the iA Innovation Council. A poll of members revealed that just under half the group was familiar with RCS prior to hearing about the term in the meeting agenda, while just over half was not. Members generated a list of exciting ways this technology could be applied. But first, a little background.

What is RCS?

In a nutshell, it’s like SMS on steroids. There are no character limits. You can include branding, color, images, documents, and even applications (think, for instance, interactive seat selection for a flight).  Most importantly, it’s native to Android devices. Rather than requiring the user to download an app (think WhatsApp, for instance), it is the default messaging app already installed on the phone. It’s the Android answer to Apple Messaging. 

One feature that’s very important to highlight is the fact that RCS includes a “verified sender” component. If truly effective and trusted by consumers, this could be a game-changer for debt collectors. It’s the concept that the calling industry is working to create through the complex STIR/SHAKEN framework. 

Here is a super quick introduction to RCS:

 

RCS isn’t actually new, so why are we now talking about it?

It’s not new. What is new is the rate of adoption. Suffice it to say, there were a lot of politics involved among major corporations around agreeing to a standard. But circumstances have evolved and it’s reached a tipping point. The Global Messaging Standards Association (GSMA) estimates that the number of monthly active users has already surpassed 300 million and that by 2021, the total market value of RCS services is expected to reach $74 billion.

And, it seems, the pandemic has only accelerated the need. According to MobileSquared,

Business messaging has never been in a better position. In fact, we’d go as far to (sic) say that the pandemic should be viewed as the defining moment that transformed business messaging from a functional channel into the mainstream alongside TV, the internet, and social media.

What are the new possibilities for consumer interaction?

These are just a few of the brainstorm ideas developed by Innovation Council members:  

  1. Use RCS to create a branded warm transfer between a creditor and agency or debt buyer. Having the logos of both companies would be preferred. It would increase the speed and level of engagement with the consumer, and the overall appearance looks more professional which may help to reassure consumers.
  2. Verified RCS is really cool as text messages are now being blocked by carriers. This would prevent that from happening. 
  3. The ability to send notices including validation is an interesting possibility. It could include buttons that consumers can click on to request validation, make payments, FAQs, etc.
  4. Use for documentation exchange for validation
  5. Leverage for payer management (e.g. issue payment reminders and allow the consumer to acknowledge a plan, or to negotiate date or amount adjustments)
  6. Use to obtain channel-specific consent
  7. Expedite the collection process – send a quick RCS message to the consumer while on the phone with them, providing the information needed allowing the consumer to make a decision quickly on the call, and proceed with payment.
  8. Before calling a consumer, an RCS can be sent as an introduction that we’ll be calling. It can provide the opportunity for self-service before making a call.

Are there compliance and regulatory questions here? Of course. And it’s important to work through them before diving in. But with that said, those who successfully improve the consumer experience and incorporate automation into their process will be the companies most likely to be left standing at the end of the day.

Want to learn more?

Here is a collection of excellent videos and whitepapers explaining RCS:

Why Is Everyone Talking About RCS Message Marketing? (~7-minute explanation, YouTube, July 2017)

RCS: Busting the 5 biggest myths (12-minute overview, YouTube, November 2018)

RCS demo (8 mins., Kroger use case, December 2018)

Is 2019 the Year of RCS? Interview with Interop Technologies (13 mins., YouTube, March 2019)

How RCS is Redefining Business Communications (whitepaper, Infobip, November 2019)

Innovation Council Logo-300px

 

 

 

 

 

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 (and lately, virtually) 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. 

2020 members include:

 

It’s Time to Think Differently About the Possibilities of Text Communication
http://www.insidearm.com/news/00046614-its-time-think-differently-about-possibil/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

How Debt Will Adapt in a Post-COVID-19 World and What that Means for Debt Collection Firms

Globally speaking, the COVID-19 pandemic has ushered a distinctive shift in the way people socialize, travel, and conduct business. In the immediate sense for the process service industry, the need to conduct a serve in person was hindered by social distancing measures. While many unprecedented uncertainties remain in the United States, economic ambiguity is steadfast, making it difficult for anyone to predict when, or how quickly, the economy will begin to recover. As a result, U.S. consumers are engaging differently with their debts.

Provided the furloughs, mass layoffs, subsequent economic downturn, there’s no surprise that Americans have started spending less and saving more. As the world settles into a “new normal,” experts in the industry suggest those involved in collecting debt should be prepared for unpredictable payments based on the ever-evolving economic situation.

It’s important for people in our industry to work backward and become familiar with how consumer and borrower behavior may be shifting as a result of this pandemic – and how they ultimately end up being served. By understanding how behaviors change, we can develop a more empathic, understanding method for our serves.

Here are three ways experts anticipate the debt collection industry is shifting in a post-pandemic world:

[article_ad]

1. Debt collectors are training and preparing staff for contextual awareness

Given today’s economic climate, debt collectors are focusing on nurturing relationships with their consumers, even before they start paying. By taking an approach to these communications, it lends itself toward being more contextually aware and helping to develop better relationships.

In times of tremendous financial adversity, like this COVID-19 pandemic, maintaining customer relationships across the debt collection process is key, especially with relevant non-account related conversations. Much like during a serve process, the best way to connect with a debtor is all about tone and timing—not increased frequency of communications.

When consumers are in a state of extreme financial stress, debt collectors and process servers alike have an opportunity to let them know that collectively, you have the same objective: To aid in their journey to get them out of debt.

Payments will inevitably be inconsistent throughout the remainder of this pandemic for many consumers, especially as individuals receive intermittent governmental aid. As businesses start to bring back their furloughed employees, spikes in payment activity could start to rise as well.

2. Debt collectors are outlining flexible options

Consumers are looking for the flexibility to pay when they can, if they can. This may mean scheduling payments to align with their pay schedule or needing help to adjust a plan to accommodate unpredictable income fluctuation.

As the past few months during this pandemic have indicated, borrowers want to feel confident they have flexibility with their payments during times of economic adversity and ambiguity. This could include modifications such as payment deferrals, extensions of repayment terms, or other insignificant delays in payment.

These adjustments could cause minor strain on short-term liquidation efforts, but over time, consumers tend to pay off the debts they feel are most manageable first. Giving consumers the flexibility to plan payments around their cash flow is not only better for customer experience, but also minimizes the risk of a failed payment due to insufficient funds and leads to lower plan breakage rates.

3. Debt collectors are looking to detail self-service options

Consumers generally take care of their financial obligations without ever talking to a human, so automation at this stage is helpful. Hopping online to interact with self-service tools with financial institutions are progressively becoming the norm, so why should interacting with debt collectors be any different?

Many debt collectors are working to configure a payment portal for borrowers so they can make a payment without having to speak with a representative. Self-service tools also mean that consumers can choose to pay whenever it’s convenient for them, not just during business hours. Digital tools should empower consumers to:

  • Defer a payment
  • Adjust the length and installment amount on their payment plan
  • Dispute all or a portion of their debt
  • Enter bankruptcy information
  • Apply for a hardship pause on their debt

What does this mean for the process service industry?

Today’s debt future is nothing short of uncertain for consumers, debt collectors, and process servers alike. Debt levels will continue to rise and consumers will undoubtedly need help. And as debt collection efforts ebb and flow, it’s important to know those behavior shifts so process service professionals can anticipate the best course of communication at the time of a serve.

Debt collectors are adapting to today’s changing market and outline an operating model that allows consumers to pay when they want to. The engagement and payment trends we’ve encountered during this pandemic indicate that debt collectors, when they appropriately train staff to provide context conscious communication, provide flexible payment options, and introduce self-service options. This parallel of empathy can also succeed during a serve.

Dave Rolf is CEO of Tag Process Service, Inc.. Founded in February 1999, the company has is a leader in process service, court filings, and private investigations for the debt collection industry. We currently serve Arizona, Nevada, New Mexico, Colorado, California, Utah and Washington with expansion plans that correlate with our client’s growth.

How Debt Will Adapt in a Post-COVID-19 World and What that Means for Debt Collection Firms
http://www.insidearm.com/news/00046602-how-debt-will-adapt-post-covid-19-world-a/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

A WCCF Video Interview Series: Five-in-Five. Amy Perkins Speaks with Roxanne Bartley

Women in Consumer & Commercial Finance is all about connection. For #fiveinfive, WCCF Chair Amy Perkins connects with sharp women from across financial services for short, intimate conversations about careers, confidence, building a mighty network, helping others and more. Check out the videos and get connected through WCCF! Registration is now open for WCCF Digital – December 8-10, from your home, desk, or anywhere you choose to be. Sign up today!

—-

Roxanne Bartley, EVP, Strategic Partnerships at Remitter

Our relationship started over our shared enthusiasm for #spartanraces and let me tell you, she is a #warrior in every sense of the word #aroo!

When she said, “…viewing things as minor detours as opposed to seeing them as road closures.”…that hit me big time. Thank you, Roxanne!

 

[article_ad]

 

 

A WCCF Video Interview Series: Five-in-Five. Amy Perkins Speaks with Roxanne Bartley
http://www.insidearm.com/news/00046608-00046609-wccf-video-interview-series-five/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

Neither Snow Nor Rain Nor Heat Nor Gloom of Night: Debt Collection and the USPS

This article, written by insideARM’s Director of Education Mike Bevel, is part of the iA Think Differently series. Written by or recorded with members of the iA Innovation Council, the series of articles and videos showcases thought leadership in analytics, communications, payments, and compliance technology for the accounts receivable management industry.

Friends, I am worried about the U.S. Postal Service.

We’ve not been kind to it in the past (all those “going postal” jokes that were never funny), and it’s not always been kind to us (who hasn’t had something lost in the mail?), but it’s in the Constitution that we have one, a Postal Service, and Things Are Afoot with it that collection agencies should start thinking about.

Putting all politics aside (even though the Post Office is a political entity), here is the issue as I see it:

The USPS has recently gone through some changes affecting the reliability of timely delivery. Current Postmaster General, Louis DeJoy, has acknowledged overall slow-downs in mail delivery. This puts some consumers in danger, especially if they have a payment that needs to be received by a certain date, or others who rely on the post office for medication.

But I worry, too, about the effect on the consumer debt industry.

If you are an agency that sends physical initial validation notices to consumers, time was (say eight months ago), you could assume that it would take up to 3 or 4 business days to reach the consumer. If you sent the letter on a Tuesday, you could expect the consumer to receive the letter by that Friday. Once the consumer has received the notice from your agency, they have 30 days to respond if they think the debt is incorrect — wrong amount, wrong consumer, wrong account, etc. So, the algorithm might be Friday + 30 days with no response from the consumer equals the date collection efforts can start in earnest without the risk of overshadowing.

But let’s say the consumer didn’t receive your mailed notice on Friday. Or Saturday. Or even Monday. What if, because of current delays with postal deliveries (on top of a pandemic complete with sporadic quarantines), the consumer doesn’t receive it until the following Tuesday — a full calendar week since you sent your inital notice. Now, the algorithm is one week after Tuesday, plus 30 days.

But you won’t know that. You won’t be alerted by the post office that your letter was delivered.

There is something called “the mailbox rule.” Boiled down to its essence, the Mailbox Rule states that mail in a mailbox, taken to the post office, dropped in a post office bin, or handed to a mail carrier, has the presumption of delivery. “At present, the ‘mailbox rule’ has provided me with some measure of comfort on the presumption of receipt,” says Manny Newburger, Founding Shareholder and Vice President of the lawfirm Barron & Newburger. “But I have been worried that a court could find the postal service’s reliability to have dropped to a point where the rule is no longer valid.”

[article_ad]

And that’s also where my concern is. You may have followed 1692g to the letter (heh), as you’re supposed to. And proof of that would stand up in court if that were the only issue. It’s those 30 days that the consumer has to respond that compels me to urge you to give this some more thought. If the consumer didn’t receive the letter on the date that your agency has assumed is the date of delivery (which is not the same as the Mailbox Rule — the Mailbox Rule, again, only asserts that mail received in any of the methods above will be delivered. But you cannot assert that the date you send the notice is the date the consumer receives the notice (unless you’re emailing — and we’ll get to that). And the consumer has 30 days. And if your collector should happen to call within that 30 day period because they are led to believe that they are in the clear to pursue collection, because your company’s delivery algorithm suggests that the 30-day period for the consumer to respond is over, they may begin collection attempts when they shouldn’t.

Several attorneys I spoke with said that almost any agency will accept a dispute or request for validation even if it’s past the 30 days — but that’s not what’s at issue here. In fact, it’s very likely the consumer’s dispute or request for validation will suffer the same fate that your initial letter did: it will be delayed by the same stresses that your initial consumer letter faced.

And that seems like overshadowing to me. And it also seems like an easy way for a consumer attorney to make a buck.

“I’ve been thinking about this, too,” says Wendy Badger, Special Compliance of Counsel for Ovaile Law Group. “It is hard to know if the algorithm needs to be adjusted for the validation period, which is counted from the day the consumer receives the notice. I don’t think it hurts to give the consumer some additional days/time to receive the notice. In my experience, most agencies who receive a request for verification of the debt send the information regardless of whether or not it is received within the 30 day validation period.”

She then went on to add a new wrinkle to the situation:

“I have a bit of a different, though related, concern when it comes to post-dated payments. The FDCPA specifically says the post-dated payment reminder needs to be sent no more than 10 nor less than 3 days before the payment will post. This is designed to remind the consumer of the payment and to take steps to have adequate funds available. With the delays I’m hearing of in postal delivery, even mailing it on the outer edge of the 10 days, the payment reminder may not get there in time. However, because the FDCPA is a strict liability statute, meaning comply exactly or be in trouble, an agency cannot mail that letter more than 10 days before the payment is scheduled to post because that would be a violation. Even though that action is intended to account for postal delays and would comply with the spirit of the law, which is that payment reminder before the payment posts, the agency would still be in violation.”

So, what’s to be done? I have several suggestions (though not to be taken as legal advice):

1) Add 10 days to your 30-day period for a consumer to dispute before fully attempting collection efforts under the belief that the debt is valid and correct.

2) Use phone calls with consumers to ask if they have received your notice in the mail.

3) Be generous with consumers whose disputes arrive after the statutory 30-day validation period.

4) Think more about an email/text approach. This will require detailed thinking and planning if you’re not already doing this; and you may need to reach out to peers in the industry to get help in making sure all the t’s are crossed and i’s dotted. (Might I suggest becoming a member of our Research Assistant program?)

5) For you compliance folks out there, consider adding “USPS” to your list of Google alerts so you are up to date on known issues, and planned solutions, for this problem.

All predictions are foolish ones in Our Current Time of Trouble. The USPS may work things out and things will go back to what we were used to. The USPS may…stop existing? Allowing the free market a chance to provide that service better. But that can also mean increased lettering costs. I would love to be able to give you a Definitive Answer, but right now all I can do is share my concern. Let me know if you’re concerned, too.

Innovation Council Logo-300px

 

 

 

 

 

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 (and lately, virtually) 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. 

2020 members include:

 

Neither Snow Nor Rain Nor Heat Nor Gloom of Night: Debt Collection and the USPS
http://www.insidearm.com/news/00046596-neither-snow-nor-rain-nor-heat-nor-gloom-/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

A WCCF Video Interview Series: Five-in-Five. Amy Perkins Speaks with Amanda Bost

Women in Consumer & Commercial Finance is all about connection. For #fiveinfive, WCCF Chair Amy Perkins connects with sharp women from across financial services for short, intimate conversations about careers, confidence, building a mighty network, helping others and more. Check out the videos and get connected through WCCF! Registration is now open for WCCF Digital – December 8-10, from your home, desk, or anywhere you choose to be. Sign up today!

—-

Amanda Bost, Director of Sales at McCarthy, Burgess & Wolff

Once upon a time, Amanda Bost saw me “alone” at a conference and what did she do? She made sure I wasn’t excluded or left behind. I knew immediately that she was my kind of people! And she has a lot of great advice to share.

And, Larissa Crum, a BIG well-deserved shout out to you, my friend.

 

[article_ad]

 

 

A WCCF Video Interview Series: Five-in-Five. Amy Perkins Speaks with Amanda Bost
http://www.insidearm.com/news/00046607-wccf-video-interview-series-five-five-amy/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance

Capital Compliance Group Welcomes Robin Borneman as Vice President of Business Development

Robin Borneman

Capital Compliance Group, the leading provider of licensing, certification, and compliance services within the collections industry, is pleased to announce their new Vice President of Business Development, Robin Borneman. Robin joins CCG with 18 years of 1st and 3rd party collection agency experience in many verticals including; student loans, financial services, government, telecommunications, and healthcare.

We are excited to have Robin join the CCG team. CCG has helped many companies with expanding into additional states, getting bonds and licensing, Debt Trader and other certifications, and compliance assistance which has led our clients to an increase in revenue. Robin’s role will allow CCG to become a greater force in the debt collection arena.

To contact Robin and find out more about how CCG can help your agency with its licensing needs, contact Robin at 612-597-8007 or email rborneman@ccglicensing.com.

[article_ad]

Capital Compliance Group Welcomes Robin Borneman as Vice President of Business Development
http://www.insidearm.com/news/00046606-capital-compliance-group-welcomes-robin-b/
http://www.insidearm.com/news/rss/
News

All the latest in collections news updates, analysis, and guidance