SAN JOSE, Calif. — The County of Santa Clara, the home of the “Silicon Valley”, has officially launched phase-one of the implementations of their new Cloud Collections Financial Ecosystem, a major milestone in the consolidation and integration of three disparate legacy systems to “CSS IMPACT! HD™ 2.0”. CSS, Inc., the developers of “IMPACT! HD™ 2.0,” is the leading provider of “NextGen” Cloud Financial Ecosystem platforms for enterprises and government.

A major hub for world renowned technology companies, the County of Santa Clara is known as “the Silicon Valley”. As such, it is not surprising that the County is a leader in innovation and digital transformation, continuously adopting cutting-edge digital tools to digitize and automate its business processes. 

“The County’s successful implementation and launch to production of our new IMPACT HD 2.0 Enterprise Collection platform will enable the county to consolidate, streamline, digitize and systematically automate many of our critical business workflows, all of which will translate to a much more efficient debt-recovery process. We anticipate that these new efficiencies will translate into increased revenues for the county, all while providing us with an unprecedented level of control. We very much value our partnership with CSS,” said Margarita Rodriguez, Director of the Department of Collections at 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 allow the county to consolidate and centralize disparate legacy systems, empower its users to deploy streamlined automated processes and make services much more efficient, effective, and transparent, all of which will lead to greater revenues to the County. We are very excited about this new partnership, and we look forward to a long-term relationship with the County,” said Carl Briganti, President and CEO of CSS, Inc.

CSS’s financial cloud architecture removes and resolves prohibitive costs of acquiring new collections and receivables “NextGen” cloud technology and workforces to overcome fundamental day to day processes. Metropolitan Municipalities, like the City of San Francisco, CA, the City of Norfolk, VA and now the County of Santa Clara, are leveraging intuitive, agile new fintech to engender turn-key automation with CSS’s Cloud Financial Ecosystem platform, enabling them to cost-effectively leverage cutting-edge Fintech technology with the added benefit of a streamlined workforce. This in turn enables County operations staff to focus solely on revenue management and customer care.

For more information, download our brochure at http://brochure.cssimpact.com or visit us http://www.cssimpact.com or call 877.277.4621. 

Please join Consumer Financial Services Partner Chris Willis and his guests, fellow Partner Alan Wingfield and special guest Tom Kline, as they discuss effective consumer complaint management. They’ll touch on the CFPB’s position on complaint management, the elements and benefits of an effective complaint management system, as well as the potential consequences of not having a complaint management system in place. They conclude the podcast by providing practical tips for handling consumer complaints.

Alan Wingfield helps consumer-facing clients navigate compliance, litigation, and regulatory risks posed by the complex web of state and federal consumer protection laws. He is a trusted advisor and tireless advocate, helping clients develop practical compliance and dispute-resolution strategies. Alan has represented banks of all sizes, bank and nonbank mortgage servicers, auto finance companies, consumer finance companies, credit card issuers, specialized lenders, franchise and independent automobile dealers, and national retailers in many individual and class-action litigations under federal and state consumer protection laws, and he has counseled these types of entities in numerous state and federal compliance issues.

Tom Kline is the founder and lead consultant of Better Vantage Point, specializing in risk mitigation by preventing and solving automobile dealership problems through risk transfer remedies, compliance, and dealership dispute resolution. He is a former franchise dealership owner with over 30 years of experience in the industry.

Transcript: Your Problems Come on Two Legs: Managing Consumer Complaints (PDF)

WILMINGTON, Del — Phillips & Cohen Associates, Ltd. (PCA), the global leader in deceased account care servicing and technology solutions, servicing clients in the United States, Canada, United Kingdom, Ireland, Australia, New Zealand, Spain, and Germany, is pleased to announce that Saima Hassan has joined as the UK Director of Operations for The Estate Registry UK (TER).

Launched in 2021, TER currently provides three innovative solutions, LegacyNOW, NotifyNOW, and InheritNOW offering digital, deceased servicing solutions in areas of life planning, executor support, and beneficiary support. 

A key pillar of PCA’s global expansion for 2023, Saima will lead TER’s operations and growth strategy in the UK. Saima joins The Estate Registry with over ten years’ experience working in the financial services market as a senior leader within outsourcing and operations management. She has a proven track record in building strategic partnerships, synergistic alliances and driving transformation. Most recently, Saima served as Head of Outsourced Collections at Arrow Global, where she led the establishment of a new business function to drive growth and innovation in the external recoveries proposition.

Adam S. Cohen, Co-Chairman/CEO commented, “We are excited to have Saima join The Estate Registry’s senior leadership team. TER’s launch in the UK is another major milestone in our mission to offer solutions that simplify deceased account servicing for everyone involved. Saima’s thought leadership and track record for success are the perfect combination to lead us into the future.”  

Hassan commented, “PCA has a long-standing reputation for exhibiting compassion and driving innovation.  When coupled with my passion and experience in delivering customer centric strategies, whilst driving transformation, PCA is a perfect fit. I look forward to working with PCA’s leadership to strengthen its customer led propositions, introducing new products, and entering new markets. I am so excited for the times ahead!” 

Amy Perkins, Chief Strategy Officer added, “Customers having access to The Estate Registry suite of services globally and the addition of Saima to the leadership team are two important steps in executing our corporate growth strategy and realizing our vision of being a leading technology provider in the compassionate care industry. We’re excited to add Saima and her dynamic leadership to our team.”

About Phillips & Cohen Associates, Ltd.

Phillips & Cohen Associates, Ltd. is a specialty receivable management company providing customized services to creditors in a variety of unique market segments.  Phillips & Cohen Associates, Ltd is domestically headquartered in Wilmington, DE, with additional offices in Colorado and Florida as well as international offices in the UK, Canada, Spain, Germany, and Australia.  For more information about Phillips & Cohen Associates visit www.phillips-cohen.com. PCA provides Equal Employment Opportunity for all individuals regardless of race, color, religion, gender, age, national origin, disability, marital status, sexual orientation, veteran status, genetic information, and any other basis protected by federal, state, or local laws.

On Aug. 11, 2022, the Federal Trade Commission issued an Advance Notice of Proposed Rulemaking seeking input that will shape potential rules “to crack down on harmful commercial surveillance and lax data security.” 

The focus of the ANPR overlaps in part with recent state consumer data privacy laws and federal legislation, but the definition of “commercial surveillance” is extremely broad and “refers to the collection, aggregation, analysis, retention, transfer, or monetization of consumer data and the direct derivatives of that information.”  

By that definition, receiving information from a consumer who applies for a loan and, using that information with permission to obtain information of their creditworthiness, would be considered “surveillance.” 

Note that the definition in the ANPR differs from the definition in the FTC’s Fact Sheet on the FTC’s Commercial Surveillance and Data Security Rulemaking where commercial surveillance is described as “the business of collecting, analyzing, and profiting from information about people.”

The ANPR provides a summary of the FTC’s history of enforcement actions related to data privacy and security and then turns to its reasons for the rulemaking, explaining that its “experience suggests that enforcement alone without rulemaking may be insufficient to protect consumers from significant harms.”

The ANPR states that part of the issue is the fact that “the FTC Act limits the remedies that the Commission may impose in enforcement actions,” since “the Commission does not have authority to seek civil penalties for first-time violations [of Section 5 of the FTC Act].”  However, trade regulation rules would remedy that issue and “incentivize all companies to invest in compliance more consistently.”

The ANPR includes 95 questions spread out among the following topics:

1. To What Extent Do Commercial Surveillance Practices or Lax Security Measures Harm Consumers?

2. To What Extent Do Commercial Surveillance Practices or Lax Data Security Measures Harm Children, including Teenagers?

3. How Should the Commission Balance Costs and Benefits?

4. How, if at All, Should the Commission Regulate Harmful Commercial Surveillance or Data Security Practices that Are Prevalent?

• Rulemaking Generally
• Data Security
• Collection, Use, Retention, and Transfer of Consumer Data
• Automated Decision-making Systems
• Discrimination Based on Protected Categories
• Consumer Consent
• Notice, Transparency, and Disclosure
• Remedies
• Obsolescence

The deadline for submitting comments will be 60 days from the date the ANPR is published in the Federal Register, and there will be a virtual public forum on Sept. 8, 2022.

AURORA, Colo. — Wakefield & Associates, a leading healthcare revenue cycle solutions company, announced today that Collect Rx has joined the Wakefield organization. Together, the two companies will leverage combined capabilities to provide a full spectrum of revenue cycle solutions, including Out-of-Network Claims resolution to healthcare providers across the country. 

Founded in 2006, Collect Rx provides a tech-enabled Out-of-Network (OON) payment integrity solution platform, assisting customers with appeals and negotiations. Combining complex claims, medical account resolution expertise, collaborative customer services, and proprietary databases, Collect Rx serves over 5,400 healthcare companies across the country. 

“Collect Rx is thrilled to bring its market-leading and provider-centric claim resolution services into the Wakefield & Associates family”, said Ike Brenner, President of Collect Rx. “Our customers and partners will be the biggest beneficiaries of this highly synergistic combination. Together, we bring to market an exceptionally comprehensive RCM solution set.”

As one of the leading revenue cycle solutions companies in the nation, Wakefield & Associates makes vital contributions to the financial health of medical providers through innovative and proven Revenue Cycle Management (RCM) solutions. 

“With its depth of expertise and being a pioneering industry leader of complex Out-of-Network claims, Collect Rx allows Wakefield & Associates to expand our service offerings”, said Matt Laws, CEO of Wakefield. “Going forward, we will be able to deliver a full suite of RCM services to the thousands of healthcare service providers with whom we partner.” 

About Wakefield & Associates

Established in 1933, Wakefield & Associates specializes in Revenue Cycle Management Solutions, which includes System Conversions, Call Center Partnerships, Insurance Billing, Process & System Workflow Design, Eligibility Assistance Programs, Primary & Secondary Bad Debt Collections, Legal Solutions, and working with Debt Purchasing providers. Wakefield & Associates has and continues to make significant investments in people, processes, and technologies that allow us to develop and implement quality solutions that accelerate cash flow and A/R liquidation. Wakefield & Associates has developed effective recovery techniques and partnership collaborations that result in a positive patient experience.

The CFPB announced that it has entered into a consent order with Hello Digit, LLC (“Digit”) to settle the CFPB’s claims that Digit engaged in deceptive acts and practices in connection with an automated savings tool it offered to consumers.  The settlement requires Digit to pay a $2.7 million civil money penalty and at least $68,145 in consumer redress.

Digit is a fintech company that offers a personal-finance-management app that includes an automated savings tool.  When signing up for the service, Digit requires consumers to grant Hello Digit access to their checking accounts.  Using its own proprietary algorithm, Digit analyzes consumers’ checking account data to determine how much a consumer should save.  It then initiates automatic electronic fund transfers (“autosaves”) to transfer money from consumers’ checking accounts to interest-bearing “for the benefit of” accounts held in Digit’s name at third-party institutions (“Digit Savings Accounts”).  Consumers are charged a $5 monthly subscription fee for this service.

The CFPB found that despite using “messaging themes to consumers” that the automated savings tool saved “the perfect amount” and that there were “no overdrafts,” Digit knew from its inception that (1) its algorithms had limitations that hampered Digit’s ability to precisely predict an appropriate amount to withdraw from consumers’ checking accounts, and (2) the autosaves routinely caused overdrafts, resulting in overdraft fees charged by consumers’ banks.  Digit also represented to consumers that if it did cause an overdraft through an autosave, it would reimburse any overdraft fees a consumer incurred.  However, Digit did not reimburse consumers for all overdrafts and received complaints about overdrafts on a daily basis.  It also retained significant interest income earned on the funds held in the Digit Savings Accounts but represented to consumers that it did not collect interest revenue.

The CFPB found that Digit engaged in deceptive acts or practices in violation of the CFPA by misrepresenting that its service would save the “perfect amount” and have “no overdrafts,” that it would reimburse consumers for all overdrafts fees caused by autosaves, and that it did not collect revenue from interest earned on Digit Savings Accounts.  The consumer redress that Digit is required to pay under the Consent Order is intended to reimburse consumers for all unreimbursed overdraft fees caused by autosaves.  The Consent Order also prohibits Digit from continuing to make misrepresentations about its automated savings tool.

In addition to serving as a reminder to companies of the need not to “over promise” in their marketing materials and to be responsive to consumer complaints, the settlement highlights two ongoing CFPB themes: a focus on overdrafts and reservations about algorithms.  With regard to algorithms, the CFPB has previously expressed concerns about fair lending risks created by the use of algorithms.  The CFPB’s prominent and repeated references to Digit’s use of algorithms in its press release appears intended to paint the use of algorithms in a negative light even outside of the fair lending context.

Finding, vetting, and on-boarding a new collections and recovery vendor is not easy or fast. You go through the trouble of wading through all of the potential vendors, assessing them, eliminating those with any red flags, and finally committing to onboard a vendor. So, whether you are outsourcing debt collections or adding new debt collections techology, you want to make sure those hard-won vendor relationships work well for you and last a long time.

Want strong vendor relationships? You need to have strong collections and recovery vendor mangement skills. How you manage those vendors will have a direct impact on how successful and lasting those relationships will be.

Good vendor management isn’t an easy job. Creditors who are too prescriptive can damage their relationships with vendors. Those who are not prescriptive enough can find themselves at risk for regulatory or reputational damage. That’s why it’s critical for collections and recovery executives to open their channels of communication, keep those channels open, and keep an open mind if they want to strike the right balance.

Here are four best practices for debt collection vendor management you can use to set up your vendor relationships for long-term success.

1. Communicate Clear Expectations to Vendors Early and Often

Collections & recovery vendors should understand exactly what their creditor-clients expect from them from the onset of the relationship.

If you’re using multiple vendors for the same process (e.g., a collections agency), it helps to standardize your MSAs/SOWs/SLAs, says Jeremy Ruth, Sr. Director of Default Account Servicing at Arvest Bank.

But don’t just hand over those expectations and expect them to be met. Collections & recovery executives should work with their vendors to create those expectations, Ruth adds. This way, you and your vendors are on the same page.

Another simple way to express expectations is to create and share a deliverables calendar, says Bekah Luebcke, VP of Operations at Crown Asset Management. Collections & recovery vendors should be able to understand performance and compliance expectations – and whether or not they’re meeting those expectations – at a glance from their scorecard, she adds.

2. Your Collections and Recovery Vendors Have Expertise – Use It

It’s critical that collections & recovery executives treat their vendor partners like experts, says Carri McQuerrey-Funk, Head of Vendor Management & Initiative Execution at Citizens Bank. She tells her vendor partners to “tell her where [she’s] being stupid,” and cautions collections & recovery vendors against feeling like they “know it all.”

“You need an expert, and they are an expert,” McQuerrey-Funk says, so when a vendor partner gives you advice, you might want to take it.

It’s also a mistake to try to off-load risk to your vendors. Not only is it no longer possible for creditors to outsource their risk, but also, trying to do so will only sour your relationship with your vendors.

The best approach is a “shared risk/shared success” approach to vendor management, advises Ruth. “You can’t look at it like you’re going to transfer risk to [your vendors]. That’s a one-sided relationship.”

3. Expand the Conversation, Connect the Experts

An ongoing collections & recovery vendor relationship typically runs through two parties: the client services manager at the vendor, and the creditor-client’s vendor manager. This is a great way to keep the relationship organized, but sometimes it’s not enough.

Connecting business units and SMEs can help you make sure that nothing is lost in translation, Luebcke explains. Some problems can only be solved by communication between business units instead of through the appointed relationship manager. It will save time and resources if the vendor’s SME can speak directly to the creditor-client SME, so don’t be afraid to take challenges out of their silos and get the real experts’ opinions.

4. Get Back to On-Site Audits

In the past, this would have been obvious. But after more than two years of a global pandemic and a major shift to remote work, many companies have fallen out of the habit. In fact, the number one question from the audience during the iA Strategy & Tech Vendor Management Masterclass webinar series was whether or not creditors were making onsite visits.

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McQuerrey-Funk, Ruth, and Luebcke, as well as T.R. Brown, VP of Consumer Finance at SmileDirect Club (all speakers on that aforementioned webinar series), all agree: If it’s safe, collections & recovery executives should be performing audits on site.

On-site audits allow you to gauge your vendor’s preparedness in a way that remote audits do not. If you’ve provided the agenda early enough, your vendor partner should have no trouble getting all the pieces in order, including getting the appropriate staff in the office prior to your visit.

If your vendor partner is disorganized during an onsite audit, for example, if they don’t have the right staff available to answer questions, it’s a signal that you may need to take a deeper dive into whether or not they are operating as prescribed by your SOW. It’s especially important to get onsite when you’re planning to audit new policies.

No vendor is perfect, but by following these four tips, collections & recovery executives can have a better chance at motivating vendors to be successful and in extending the success and the lifespan of any vendor relationship.

For more on how to successfully manage your vendors, check out The Vendor Management Masterclass II.

Bonus read: Creditors: Can You Outsource Risk by Outsourcing Collections? Not Anymore.

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Are you interested in Digital Collections and Recovery Strategy Best Practices? If so, you can find the (free!) iA Strategy and Tech Short Guide Digital Collections and Recovery Strategy Best Practices in 2022. You can find resources like this as well as the latest trends in collections and recovery strategy, digital debt collection, vendor management, and compliance in the iA Strategy and Tech newsletter. To get these insights delivered directly to your inbox, sign up here.