Recently, the Third Circuit Court of Appeals provided a reminder that demand letters subject to multiple interpretations violate the Fair Debt Collection Practices Act (FDCPA). Of perhaps more importance, despite pre-dating Reg F, the case illustrated the difficulties of collecting medical debt and accurately conveying medical debt balances to past due patients. 

In Huber v. Simon’s Agency, Inc., 22-2483 (3rd Cir. Oct 12, 2023) a patient filed a class action lawsuit alleging that a letter a debt collection agency sent to collect a medical debt was confusing and thus violated the FDCPA. The letter included an ‘Account Summary’ that provided the two figures: in one box, the specific debt the debt collector sought to collect, titled ‘Amount,’ and in another box, a second figure, titled “Various Other Accts Total Balance.” The patient alleged the two boxes were confusing because they could be read in multiple ways.

The letter at issue, sent September 6, 2018 was the fourth letter the debt collector sent. Previous letters were sent May 24, 2018, June 14, 2018, and July 12, 2018. The debt collector challenged the class allegations, the patient’s standing to bring the action, and argued that the patient could have deduced the meaning of the letter by comparing the September letter with the May, June, and July letters. Specifically, the debt collector explained, “Each correspondence was about a separate account and the ‘Total Balance’ identified increased each time by the amount owed for that specific amount.”

The court rejected the debt collector’s argument. Noting that the fourth letter was sent nearly three months after the first and second letters and nearly two months after the third letter, the court opined that in those intervals a patient “may have lost the [prior letters] and forgotten the amount of the debt completely.” Thus, because the letter could be read two different ways, and one of those ways was inaccurate, the court found the letter was deceptive and violated the FDCPA

insideARM Perspective: 

Though the letters sent in this case pre-date Reg F, the Huber case still provides a valuable lesson. Collecting medical debt can involve multiple doctor visits, multiple accounts, and detailed accounting and collection agencies have struggled to present accurate information both within the confines of the Model Validation Notice and without. With the disclaimer that you should always consult with your own counsel, all debt collectors, and especially those who collect medical debt, should look at their letters through the eyes of the consumer or patient. Make the letter as clear as possible and spend time evaluating whether your letters can be subject to multiple interpretations, whether or not your agency chooses to use the Model Validation Notice.

In September 2023, the CFPB updated its UDAAP Examination Manual to remove the changes it made in March 2022 which provided that unfair acts or practices encompassed discriminatory conduct, even in circumstances to which federal fair lending laws, such as the Equal Credit Opportunity Act, did not apply.

It has been suggested that this update means the CFPB has retreated from its position that discriminatory conduct can be the basis of a UDAAP violation.  In our view, the update has little significance and was intended only to implement the Texas district court’s order vacating the March 2022 changes.  We do not believe it should be seen as an indication that the CFPB has decided to revisit its interpretation that unfairness can encompass discrimination.  

The CFPB’s continuing adherence to its interpretation is evidenced by the fact that the CFPB has filed a notice with the Texas federal district court that it is appealing its order to the Fifth Circuit.  In its briefing in the district court, the CFPB took the position that the source of its authority to interpret the unfairness prong of UDAAP to encompass discrimination is the unfairness prong itself, and its interpretation did not need to be effectuated through the changes it made to the UDAAP Exam Manual.  Thus, the CFPB in effect has argued that the changes it made to the Exam Manual were superfluous.  

In that regard, there has been some confusion about whether the CFPB’s appeal is timely.  Under the Federal Rules of Appellate Procedure, non-governmental parties must file a notice of appeal within 30 days but the government has 60 days in which to file a notice of appeal.  The district court’s order was entered on September 8 and the CFPB filed its notice of appeal on November 6.  Accordingly, there is no question that the CFPB’s appeal is timely.

In the first blog of this series (Unlock the Power of Data: The Key to Successful Digital Debt Collection), we discussed why setting up a robust data collection process is the foundation for an effective digital collections strategy. Even with a good dataset on file, your data is worthless if you aren’t able to extract the proper insights from thorough and meaningful data interpretation and analysis. Because these insights drive how you engage with your customers on an ongoing basis, they can make or break the quality of those interactions. Thorough and meaningful data interpretation and analysis are areas in collections, in which many organizations can fall short.

This blog, the second in this series, explains the importance of taking a methodical approach to debt collection data analysis to validate findings that will enhance your existing contact strategies and enable a positive customer experience.

1. Define the question or use case being solved to determine your data sources.

Your understanding of the business goal and objective allows you to identify which data sources to include or exclude. You’ll also need to establish Key Performance Indicators (KPIs). Once you have those business goals, objectives and KPIs, measure your results back to the source to ensure that you have the right data to report on and can effectively track results.

2. Practice good data hygiene by removing bad data.

As the saying goes, “bad data in, bad data out.” Inaccurate debt collection data analysis will deliver flawed insights that can both harm the customer experience and invite unwanted regulatory exposure on you, the lender. To avoid this pitfall and create an accurate analysis framework, ensure that you have a structured data set and remove:

• Irrelevant data points
• Invalid fields (e.g., a date where a dollar amount should be)
• Duplicates
• Data that cannot be tracked back to the SOR (e.g., calculated fields).

3. Analyze trends and patterns closely to find customer behavior patterns.

Try overlaying customer profile data points with digital response rates to help you determine critical customer behavior patterns. You might find that certain risk segments and demographics have a higher response rate to SMS versus email, or that younger customers may prefer to pay via mobile. As an example, for one UK lender’s early-stage credit card and portfolio strategy, I saw that SMS yielded a higher click-to-payment rate versus email.  Of the customers who opened the SMS, 90% logged into the self-service option and an additional 50% scheduled a payment. In another test conducted for that same lender using a US charged-off credit card portfolio, three quarters of customers who did not answer a phone call did choose to open an email.

4. Act on the new information that you’ve learned.

Combining updated information from your customers with the data you have on file is a very powerful part of your contact strategy. Pre-emptive contact strategies are a natural way to retain customers, build loyalty and verify demographic information before a customer falls past due. Do this by proactively soliciting key information from a customer before they are in collections. You can gain information during the application/originations process, during servicing and part of your ongoing strategy.

Having an interactive SMS, E-mail, WhatsApp, or other digital mechanism not only makes it easy for the consumer to communicate, but also will reduce inbound call volumes.  If a two-way contact strategy foundation exists within your company’s infrastructure, then it is most critical to store and track that information correctly in your pre-defined data structure. In an SMS message, you have 160 characters to convey the call to action to the customer, such as Thank you for being a loyal customer, we would like to offer a promotional interest rate of X for the next Y months. Please click the link to opt in or Thank you for being a valued customer, please confirm if text is still your preferred contact message. Reply STOP to opt-out. The continuous updates that you collect will allow you to effectively refine your contact strategy.

5. Align your strategy across platforms to simplify the customer journey.

Another critical component that is often overlooked is whether the lender has the operational readiness to complement the desired digital strategy outcome. Often, I find that the tools (offers) agents have to discuss with the customer are not aligned with the digital channel tools. As a result, the customer may receive different offers from different platforms (for example, call center versus email). Misalignment here creates a confusing journey for your customer AND your agents.

At the end of the day, while these five actions cover a diverse range of areas, they all have something in common: They each require that you employ a customer-centric view to your contact strategy to successfully execute in each channel.

Maintain Focus on the Customer Throughout your Digital Collections Strategy

Keep the customer-centric mindset throughout planning and executing your digital collections strategy.  And, at a minimum, clearly communicate all contact strategy changes to the operations team in advance, including your agents. In fact, if it’s possible, train your agents on the changes to your strategy to ensure that they can effectively support it in their customer interactions.

BIRMINGHAM, Ala. — McGlinchey Stafford is pleased to announce the addition of Colin T. Dean to our Birmingham office as Of Counsel. Colin is joining the firm’s Financial Services Litigation practice group, bringing valuable experience to this team’s nationally recognized group of attorneys.

“We are excited to welcome Colin to our growing bench of versatile litigators here in Birmingham,” said Chris Bottcher, Managing Member of the firm’s Birmingham office. “His commitment to providing tailored solutions and adept navigation of regulatory complexities make him a welcome resource for our team and clients alike.” Colin is the third attorney to join McGlinchey’s Birmingham office in the past year.

Colin’s practice encompasses financial services litigation, transactional matters, and FINRA arbitrations  across multiple states, including Alabama, Florida, and North Carolina. He skillfully represents mortgage lenders, loan servicers, and other consumer lenders facing individual and class action claims involving fraud, breach of contract, and violations of consumer protection statutes. Specifically, he advises on disputes brought under the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Fair Housing Act (FHA), the Fair Credit Reporting Act (FCRA), the Telephone Consumer Protection Act (TCPA), and the Fair Debt Collection Practices Act (FDCPA), as well as their state counterparts. Colin also provides guidance on regulatory matters.

“Having worked with Colin in the past, it is my privilege to add an attorney of his caliber to our national team,” said Shaun Ramey, co-chair of McGlinchey’s Financial Services Litigation group. “His 360-degree perspective on the financial services industry positions him to meet our clients’ diverse needs.”

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Before joining McGlinchey, Colin served on an in-house compliance team, advising senior management and internal business units on contract negotiation, drafting, interpretation, and review within the reinsurance division of a national life insurance company. He brings more than a decade of experience in private practice, focusing on both consumer financial services litigation and compliance.

Colin earned his J.D. from the University of Alabama School of Law, magna cum laude, and holds a B.S. in Public Relations from the University of Florida. He is admitted to practice in Alabama, Florida, and North Carolina.

About McGlinchey

McGlinchey Stafford is a premier midsized business law firm offering services in nearly 30 practice areas through a highly integrated national platform. McGlinchey attorneys leverage bold innovation, diverse talent, and leading-edge technology across our powerful network to serve clients at the local, regional, and national level. With nearly 160 attorneys licensed in 34 states, McGlinchey operates from 17 offices nationwide. The firm currently has 23 attorneys and 12 practice areas recognized in Chambers U.S.A. and Chambers FinTech 2023, and 65 attorneys recognized by Best Lawyers, 40 attorneys recognized in various Super Lawyers rankings, 44 practice areas recognized by Best Law Firms, and was named a “Top Performer” by the Leadership Council for Legal Diversity (LCLD) since 2018. To learn more, visit www.mcglinchey.com.

MINNEAPOLIS, Minn. — DCM Services, Inc. (“DCMS”), the industry leader in estate and specialty account recovery solutions, is pleased to announce the appointment of Steve Barker as Senior Vice President of Human Resources. 

Steve has been a leader in Human Resources for over 20 years and brings expertise in aligning strategy, people, capabilities, and culture to deliver results and accelerate growth. He has held various leadership positions at top-tier organizations, most recently at Garda Capital Partners, Securian Financial, and U.S. Bank where he partnered with executive management and provided strategic HR solutions, aligned with business objectives, aimed to help achieve and exceed business goals. He has built his career in various HR leadership positions, evolving HR from traditional task-oriented operations to one focused on PEOPLE throughout their entire life cycle, from recruitment to retirement. 

Michael Rosenthal, Chief Executive Officer of DCM Services commented, “Steve is an accomplished human resource leader who has proven to be innovative and a proactive advocate for employees. DCMS employees are critical to our success and I am thrilled to have him on board, and look forward to his enhancement of our HR strategy.”

About DCM Services

Minneapolis-based DCM Services is the industry leader in estate and specialty account resolution services, maximizing the value of client portfolios across financial services, healthcare, auto, retail, telecom, credit union, government, and utility industries through innovation and performance. Its recovery solutions offer a full range of services, from proprietary web-based solutions to full outsourcing, maintaining an unmatched spectrum of innovative solutions that increase recoveries, protect brand value, and enhance survivor relationships – with respect and sensitivity. For more information on all DCM Services’ offerings, please visit www.dcmservices.com.

WASHINGTON, D.C. — The National Creditors Bar Association (NCBA) announced on November 13, 2023 the appointment of Daniel Lipner as VP of Government Affairs at the federal level. The appointment represents an addition to NCBA’s government affairs team and comes at a time when NCBA’s impact and influence are growing.

Due to member requests for increased support on state level issues and our growing influence in Washington, we decided, with the support of the Board, to separate the Government Affairs Officer position into two distinct roles: State and Federal. Nathan Willner, as the VP of Government Affairs (State), will continue his indispensable advocacy work at the state level including working with State Creditors Bar Associations (SCBAs) and sister trade associations. The collaboration of Nathan and Dan will create an even more robust advocacy team, ensuring NCBA’s place at the legislative and regulatory tables of power.

An Emory Law graduate with over 20 years of experience as an attorney and political consultant, Daniel has experience with political and issue campaigns, lobbying, grassroots organizing, relationship building, communications, and political crisis management.  He has worked on Capitol Hill, in the White House, at the National Labor Relations Commission, for nonprofits, and at private law firms. 

“Daniel’s appointment comes at a pivotal time for NCBA as state issues ramp up, but we cannot let our guard down on the federal issues impacting our membership. Adding this position means creditors rights attorneys will have a voice and seat at the table on state and federal issues, requiring the full team and collaborative efforts of Nathan and Daniel,” said Liz Terry, Executive Director, NCBA. “We look forward to Daniel’s efforts and advocacy on the Hill. This will help us strengthen existing relationships and broaden our reach on behalf of our more than 1,700 attorneys and roughly 350-member law firms.”

“I am excited to join the team of phenomenal professionals at NCBA, and I’m already impressed by the work being done,” Daniel said on day one. “I see tremendous opportunities to expand the footprint of our organization and our membership locally and nationally to ensure that NCBA is not only at the table when decisions are made but recognized as the sought-after expert representing creditors rights attorneys.”

To increase the involvement and awareness of the creditors rights practice of law, Daniel will manage NCBA legislative and regulatory efforts at the federal level. He will also support NCBA judiciary efforts and work with sister trade associations to help advance the creditors rights industry.

As a team, Nathan and Daniel will report to Liz Terry, Executive Director, and continue to advocate and grow NCBA’s presence at the State, Federal, and Grassroots levels.

About National Creditors Bar Association (NCBA)

NCBA is the premier bar association dedicated to serving law firms engaged in the practice of creditors rights law. Currently, our membership is comprised of over 350 law firms and individual members, totaling approximately 1,700 attorneys, in the areas of creditors rights law, defense and in-house counsel. Members practice in over 20 different practice areas in the 50 states, Puerto Rico, and Canada. Our attorney members are committed to being professional, responsible, and ethical in their practice and profession. http://www.creditorsbar.org

A U.S. District Court in the Western District of Wisconsin recently denied both the defendant and plaintiff’s summary judgment motions in a Fair Credit Reporting Act (FCRA) case, holding that the reasonableness of the defendant’s investigation of the plaintiff’s identity theft claim was a triable issue.

In Simonson v. IQ Data International, Inc., the plaintiff’s identity was stolen and used to rent an apartment in Arizona. When the fraudster fell behind on payments, the apartment leasing company hired the defendant, to collect the unpaid rent. The defendant contacted the plaintiff about the debt in April 2021 and was informed that the plaintiff never lived in Arizona and was the victim of identify theft.

The defendant instructed the plaintiff to submit a written dispute, including the police report. Later, one of the defendant’s representatives called the fraudster and the plaintiff on the same day and admitted that the plaintiff did not sound like the fraudster. In August 2021, the plaintiff submitted a dispute to the consumer reporting agencies (CRAs) asserting that she was the victim of identity theft. Following her dispute submission, one of the CRAs did not remove the account from the plaintiff’s report and the defendant continued to report the account as disputed.

To prove the validity of her identity theft claim and have the reporting removed, the plaintiff mailed a letter to the defendant using her employer’s Wisconsin letterhead that repeated her statement that she was a victim of identity theft and provided a copy of the police report. The defendant received the plaintiff’s letter and sent a response asking that she provide additional information, including paperwork demonstrating proof of residency during the time the identity theft occurred. The plaintiff never received the letter because it was misaddressed.

When the reporting continued, the plaintiff sent additional disputes to the CRA supporting her identity theft claim, including copies of her driver’s license and the police report. The defendant received the dispute and supporting documents but did not cease reporting on the account. After submitting a final dispute in February 2022 that resulted in no change in reporting, the plaintiff filed suit against the defendant alleging it violated the FCRA by failing to reasonably investigate her identity theft claim.

The parties filed cross-motions for summary judgment. The district court judge denied the motions finding the reasonableness of the defendant’s investigation was “a factual issue typically reserved for trial” unless the defendant’s procedures were reasonable or unreasonable “beyond question.”

In addressing the defendant’s motion for summary judgment, the court distinguished the case before it from Woods v. LVNV Funding, LCC, where the Seventh Circuit Court of Appeals affirmed summary judgment for a furnisher who stopped its investigation of a consumer’s identity theft claim after the consumer failed to respond to the furnisher’s request for more information. According to the court, Woods was distinguishable because there the furnisher had affirmative evidence that the information it possessed on the consumer was accurate while here the defendant had no information accurately linking the plaintiff to the Arizona debt. Additionally, the court found the plaintiff in this case continued to file disputes about the debt and provide corroborating information verifying her identity theft claim after the defendant sent the letter requesting additional information while the plaintiff in Woods did not. Although the plaintiff did not provide a copy of the information specifically requested by the defendant, in subsequent disputes she did provide a copy of a Wisconsin driver’s license that matched the address listed on her police report. The court found that in light of the plaintiff’s actions a reasonable jury could determine that the defendant should have taken additional steps to investigate her claim.

However, the court also denied the plaintiff’s motion for summary judgment holding that there was some uncertainty regarding whether a jury would find the defendant’s investigation of the plaintiff’s identity theft unreasonable. Specifically, the court noted that the plaintiff cited no caselaw holding a furnisher’s investigation was unreasonable as a matter of law, there was evidence that the defendant acted reasonably by promptly requesting the plaintiff provide additional information, and despite the plaintiff providing additional information, the plaintiff did not provide the specific information requested by the defendant.

On October 25, the CFPB released a report on credit card interest rates and fees in 2022 highlighting the impact of the cost to consumers. The report found that credit card companies charged consumers more than $105 billion in interest and $25 billion in fees, with the bulk of the fees being late fees.

According to the 175-page report, consumers are rolling balances month-to-month, falling into debt, while credit card companies’ profit margins remain high. The CFPB highlighted additional trends, including how 

1. the profits of major credit card companies have increased, surpassing pre-pandemic levels, which could indicate a lack of competition in the industry, with a few dominant players; 

2. Annual Percentage Rates (APRs) for credit cards continue to rise above the cost of offering credit (meaning cardholders are paying more in interest); 

3. many cardholders with subprime credit scores paid a significant percentage of their average balance in interest and fees; 

4. late fees charged to cardholders have risen to pre-pandemic levels, and more consumers are delinquent; 

5. credit card debt reached a record $1 trillion by the end of 2022, and annual spending on credit cards increased, returning to pre-pandemic levels; and 

6. consumers who roll debt from month to month are paying a significant portion of interest and fees but earning only a small percentage of rewards. 

The report also notes a rise in digital communication—around 80 percent of cardholders, especially those under 65, use mobile apps for card management, which exhibits a shift in how consumers and financial institutions interact in the credit card industry.

TREVOSE, Pa. — NCB Management Services, Inc., a respected national Debt Buyer and leading provider of Accounts Receivable Management (ARM) solutions, is pleased to announce the appointment of David Morton as its new Director of Business Development.  In this role, David will play a key part in driving the company’s growth strategy and fostering strategic partnerships.

With more than two decades of experience in the financial services industry, David brings a wealth of knowledge and expertise to NCB Management Services, Inc. His proven track record in business development, client relationship management, revenue generation and operational management will be instrumental in further expanding the company’s presence and driving new business opportunities.

Prior to joining NCB, David held senior positions in various reputable organizations, where he successfully led business development initiatives, managed key client relationships, and consistently exceeded sales targets. His exceptional ability to identify market trends and capitalize on emerging opportunities will be a valuable asset in NCB’s continued growth and success.

“We are thrilled to welcome David Morton to our team as our new Director of Business Development,” said Ralph Liberio, President & CEO of NCB Management Services, Inc. “David’s extensive experience and strategic mindset perfectly align with our company’s mission and vision. We are confident that his strong leadership skills and client-centric approach will further enhance our ability to deliver exceptional solutions to both our current and future business partners.”

As the Director of Business Development, David will be responsible for spearheading the company’s sales and marketing strategies, identifying new business opportunities, and nurturing relationships with key stakeholders. His primary focus will be on expanding NCB’s footprint in the market and solidifying its position as a trusted partner in the accounts receivable management industry.

“I am honored to join NCB Management Services, Inc. and be part of this dynamic and innovative team,” said David Morton. “I am excited about the opportunity to contribute to the company’s growth and success by leveraging my expertise and building strong partnerships. ”Together, we will continue to deliver outstanding results for our clients and drive sustainable business growth.”

About NCB Management Services

NCB Management Services, Inc is a customer-centric, regulatory compliant organization who is a well-respected Debt Buyer of Unsecured Consumer Credit Products and an admired, well-recognized Accounts Receivable Management (ARM) industry leader. NCB is a leading provider of accounts receivable management solutions.  With a strong commitment to compliance, ethics, and customer-centric approach and service, NCB offers comprehensive and customizable solutions to help businesses optimize their revenue cycle and improve financial performance, while meeting the needs of their customers. Through a combination of advanced technology, industry expertise, and exceptional customer care, NCB has developed a reputation as consistently being a valued business partner and performer in a wide variety of applications. Providing superior customer interaction and achieving maximum results, while protecting NCB’s and our client’s valued reputations, are among our highest priorities.

The goal of a recovery operation is to maximize profitability by efficiently recovering money lent to consumers—while maintaining consumer loyalty. This means that measuring the success of a recovery strategy goes beyond just dollars and cents and into consumer-centric metrics as well.

But how do teams measure overall portfolio performance, and what are the most important portfolio-level key performance metrics (KPIs)? Let’s take a look at a few of the top KPIs and how they can be categorized.

Key Collections Metrics

Key performance indicators for debt collection and recovery efforts:

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• Accounts per Employee (APE) or Accounts to Creditor Ratio (ACR): the number of delinquent accounts that can be serviced by an individual recovery agent

• Net Loss Rate or Net Charge Off Rate: measures the total percent of dollars loaned that ended up getting written off as a loss

• Delinquency Rate: total dollars that are in delinquency (starting as soon as a borrower misses a payment on a loan) as a percentage of total outstanding loans – often an early warning sign on the total volume of delinquent debt

• Promise to Pay Rate: the percentage of delinquent accounts that make a verbal or digital commitment to pay

• Promise to Pay Kept Rate: the percentage of delinquent accounts that maintain a stated commitment to pay

• Roll Rate: the percentage of delinquent dollars that “roll” from one delinquency bucket to the next over a given period of time – provides visibility into the velocity with which debts are heading into charge off

Metrics like net loss rate are the north star of a recovery program, while metrics like delinquency rate and roll rate are leading indicators of future portfolio performance. But just as critical as these traditional KPIs, today’s collection operations need to focus on implementing and measuring digital engagement.

Digital Engagement Metrics

A range of KPIs that capture how effectively digital channels are reaching and engaging consumers:

• Coverage: the percentage of users for whom we have digital contact information

• Deliverability: the percentage of digital messages that are actually reaching consumers

• Digital Opt-In: the percentage of users who have consented to receive digital communications in a particular channel

• Open Rate, Clickthrough Rate: the percentage of users who are actually opening and clicking digital communications

Following key collection and digital engagement metrics are all well and good, but how do recovery teams move the needle on those critical KPIs?

Operational metrics are the KPIs that collectively drive overall portfolio-level performance. They represent the “levers” available to change the economics of a recovery model.

Operational Metrics 

Metrics that create simple framework to explain the profitability of a recovery operation: 

• Profitability of a Collections Operation Formula: R x ResF x E

• R [Reach]: percentage of consumers in delinquency can you actually reach

• ResF [Resolution Funnel]: how effectively you can convert initial contact with a consumer into a commitment to pay – and ultimately, a payment promise kept (see Promise to Pay Rate and Promise to Pay Kept Rate)

• E [Efficiency]: calculation of what the “unit economics” of your collection are and how much it costs, on average, for every account that you rehabilitate

In the hyper-competitive financial services space, consumer experience is a source of competitive advantage. That’s why it stands to reason that alongside the “traditional” metrics of recovery economics, forward-looking businesses have pioneered a new set of KPIs that measure the value of consumer experience.

Consumer-Centric Metrics 

A new set of KPIs that measure the value of consumer experience:

• Net Promoter Score (NPS): how likely a consumer is to recommend a given brand after an experience with a brand’s collection organization

• Customer Retention Rate: how likely a consumer is to be reacquired by a given brand after his or her delinquent account is rehabilitated

Keep a Close Watch on These KPIs for Collection

As payment-driven organizations across verticals focus further into the world of recovery, it is safe to anticipate that digital engagement and consumer-centric KPIs like the ones we covered above will become even more deeply woven into the fabric of the organization.