With rapidly-shifting technology, regulations, and demographics, the collections industry is facing a wide range of challenges. In today’s highly-mobile society, debtors are more difficult to locate than ever before. Although there is a surplus of information available on individual debtors, it can be nearly impossible to effectively sort through it all.

Thomson Reuters recently surveyed its collections clients to discover the most pressing debt collection challenges currently confronting them. The top four reflect their mutual frustrations with finding good, reliable information on debtors.

Which of the following challenges did your organization experience prior to using CLEAR for skip tracing?

1. Lack of current contact information of debtors

Why is this a challenge?

In the digital age, there is rarely a shortage of information available about an individual, but finding the most up-to-date, accurate contact information of a debtor can often be a big problem. 

After all, successful recoveries are based on the ability to contact the debtor. Without current information for the debtor, it’s nearly impossible to contact him or her – and thus impossible to recover the debt.

What causes it?

An organization can lack current contact information on a debtor for a number of reasons: The debtor regularly moves; perhaps the contact information used for the original credit is out of date; maybe the debtor lives with a third party who is the primary owner or tenant of the property; or maybe there’s just an incorrect entry for the debtor in one or more of the available databases.

The list can go on, and gets even longer when considering the newest generation of debtors. However, technology will only be making more individual information available in the future, rather than limiting it. So, even if “too much” information is a problem, it’s not one that is going to be solved by reducing the amount of available entries on a debtor.

Instead, a lack of information verification is truly at the root of this problem – and consequently, the solution lies in establishing one or more methods of information authentication, such as ensuring data is updated in real time and having transparency in information sources.

2. Difficulty in identifying and contacting debtors

Why is this a challenge?

It should be obvious why not having enough information to identify and contact debtors is a problem. Once again, this issue creates a serious barrier to contacting debtors, which itself prevents successful recoveries.

But this challenge may feel especially frustrating, since the lack of information is more than just a waste of time and resources; it often prevents any action from being taken on an account altogether.

What causes it?

In some instances, an organization may not have enough information to successfully identify or contact a debtor because there simply isn’t enough information on the individual in public records. But, considering the magnitude of data captured and stored in public records, this is likely rarely the case.

Instead, most of the time, the facts about a debtor are out there, but organizations run into difficulties with identification and communication because the information isn’t where one would expect it to be. This can happen for a variety of reasons, and getting around the problem often demands a broader, more comprehensive look at public records, such as scrutinizing a debtor’s third-party connections, for example.

3. Difficulty in accessing the most valuable information

Why is this a challenge?

For some debtors, the information most likely to lead to a successful recovery isn’t something basic like a phone number or address. It may be data about their place of employment or known associates.

Unfortunately, this information isn’t nearly as accessible as the more straightforward records. This, in turn, can create the problem of additional time wasted trying to locate and access this data, or attempting a less effective recovery without it.

What causes it?

The cause of the problem is the raw complexity of public record databases and the ability to access the information. It may not be possible to access any public record from any platform or for any purpose. The solution is to either have your organization become well-versed in accessing these databases – which may not only consume substantial time, but also some associated monetary costs – or to pay someone else who already has the infrastructure set up to get the information that you need quickly and easily.

4. Takes too long to locate debtors when sorting through all the data

Why is this a challenge?

This is, once again, a problem of “too much” information. But beyond determining whether the contact information is the most current, this problem encompasses the extra time spent trying to determine which information is best for reaching the target.

As the adage of “time is money” certainly applies in collections scenarios, it is unwise for organizations to spend too much time on a single account. However, it’s also crucial to ensure the information you’ve gathered is the kind of information that will lead to a recovery. This is especially true for accounts with an overabundance of available data. 

What causes it?

In short, this is caused by too much information without enough organization. All the information about a specific debtor should be evaluated to ensure the most effective recovery effort possible. On the other hand, there is so much data available on individuals today that it is often not feasible to manually comb through every record.

As with Challenge #3, unless your organization is able and willing to create a cost- and time-effective solution, the best answer to this challenge is to find a public records platform that does the organizational heavy lifting for you.

In fact, considering that accessing and managing data are at the root of all four of these problems, the key to solving all of them may simply be to leverage a platform that specializes in those specific features.

Thomson Reuters CLEAR is such a platform. As the next installment will discuss in detail, CLEAR addresses all of these top debt collection challenges comprehensively through access to numerous public records databases, with the information updated in real time and organized in a clean, easy-to-understand interface.

How Thomson Reuters Can Help 

If your information is inaccurate or outdated, it will either take too long to find the right people or you’ll waste time and resources searching for the right data. Thomson Reuters CLEAR for Skip Tracing provides access to transparent sources with easy access to scope and update frequencies. Now you can feel confident that you’re accessing the most current and comprehensive data.

• Access key proprietary and public records in one intuitive environment
• Enable batch alerting to run one search for a large number of people and businesses
• Receive real-time records such as arrests, watch lists, and social media
• Instantaneously analyze search results to shorten investigation time and uncover hidden unknowns

Request your FREE person or business investigations search 

Thomson Reuters is not a consumer reporting agency and none of its services or the data contained therein constitute a ‘consumer report’ as such term is defined in the Federal Fair Credit Reporting Act (FCRA), 15 U.S.C. sec. 1681 et seq. The data provided to you may not be used as a factor in consumer debt collection decisioning, establishing a consumer’s eligibility for credit, insurance, employment, government benefits, or housing, or for any other purpose authorized under the FCRA. By accessing one of our services, you agree not to use the service or data for any purpose authorized under the FCRA or in relation to taking an adverse action relating to a consumer application.

 

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Just a few years ago, FDCPA litigation had many in the collection industry were wringing their hands in frustration. The Douglass decision on innocuous information appearing in the windows of envelopes spawned hundreds of class action lawsuits; claims regarding the tax implications of settlements, voicemail message content and call frequency were on the rise; and, lawsuits with collection calls “scripted” by consumer attorneys were being filed nearly every day. 

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Today, all of these issues are (mostly) in the past as debt collectors focus even more heavily on compliance and a number of positive Court decisions put to rest questionable legal theories upon which these FDCPA cases relied.  However, it is only a matter of time before new theories arise. 

In the latest episode of the Debt Collection Drill, Moss & Barnett attorneys John Rossman and Mike Poncin explore how the FDCPA landscape shifted and identify ways in which collectors can avoid being caught in the inevitable next wave of FDCPA lawsuits. 

Click here to listen to the podcast.

The FDCPA says that collectors may not communicate about a debt with a third party, except in limited circumstances. I have no problem with the spirit of this requirement. What has become unworkable is the expansive definition of what is effectively inadvertent “communication” with third parties.

In years past this clause gave rise to volumes of litigation related to leaving voicemail messages, because standard voicemail technology required a consumer to listen to a recording in the open, where others might hear. And access to the voicemail was available simply at the click of a button on the machine.

Today, these devices are in far fewer homes, and the vast majority of consumers have the ability to hear voicemail messages in private, with a password typically being required for access. Yet collection agencies are still reluctant to leave messages. In its Outline of Proposals released in conjunction with the 2016 Debt Collection SBREFA hearing, the CFPB suggested a fix to this situation by offering a limited content message that can safely be left and not be deemed a “communication” under the FDCPA. That’s helpful, but really the root of the problem goes further.

There are now parallels for this scenario in countless other communication channels.

eMail

Collectors must undergo contortions to use a decades-old ubiquitous communications “technology” called email. Because a neighbor might see the contents of an email? How… over my shoulder? Or my child might use a shared family email? Email accounts are free. Consumers can have as many as they wish. Why use a family email to open an account, or communicate with a healthcare provider?

In spite of being a well-established, ubiquitous, and generally free-to-the-consumer communication channel, collectors are unable to use it to reach consumers; not so much because the regulations say they can’t, but because they don’t say they CAN, and therefore creditor clients in general will not allow it.

Mobile phones

The proliferation of illegal and unwanted robocalls has stirred a massive effort to put tools in between call originators and called parties. Dozens of applications have been developed with the goal of notifying a consumer who is calling, and WHY, in order to provide them with enough information to determine whether to answer a call. As consumers, we all love this. However, collectors are the ONE INDUSTRY faced with a unique challenge in this new scenario. Should one of these applications disclose on a consumer’s mobile phone screen that a debt collector is calling, would be a third party disclosure? 

This situation has caused the industry to come up with alternate terminology to suggest to application providers that vaguely – but accurately – describes the call. At the moment, this is “account servicing.” So, what happens when account servicing becomes synonymous with debt collection? Another term must be found? How long will it take for a clever consumer attorney to file a lawsuit against the application provider, the carrier, and the debt collector, saying “account servicing” misled their client into picking up a call from a debt collector?

But, the whole point of the technology is to give the consumer accurate information.

This is endless. The broad interpretation of this rule may be protecting a small slice of consumers, but it is inconveniencing the vast majority who need the ability to communicate about debts in their preferred channel. The more barriers we put in front of this goal, the more we end up with debts on credit reports, debts turning into lawsuits, and debts getting re-placed with multiple collection agencies or sold because of an inability to communicate and resolve.

It is time to revisit this definition of third party communication. 

—

Editor’s note: You may also be interested in this related post today about an updated way for legitimate callers to ensure their calls are properly labeled.

First Orion, the company behind PrivacyStar, has re-launched its portal that allows legitimate call originators to register their phone numbers and access an avenue to correct improper call labeling. The portal, which originally launched in beta last fall, is called CallTransparency.com. 

According to an announcement by the company, this new version also includes — at no charge — a Number Reputation Service (NRS) that calling parties can subscribe to that will monitor the Nuisance Score for their phone numbers, provide periodic reports on what’s happening and alert the owner if an unusual spike occurs. As an example, First Orion says it will help legitimate, verified brands know when their numbers have been illegally spoofed or are getting a negative reaction from individuals (e.g. high number of blocks and complaints). 

The company says,

The Registry ensures legitimate businesses are employing valid numbers and protects them from being labeled as scam. In addition, The Registry also summarizes areas where bad practices may be causing high nuisance perception and enables correct categorization of phone numbers.

As soon as legitimate businesses register and their numbers are verified First Orion will display as such throughout First Orion’s network of influence. To ensure the highest level of accuracy, First Orion validates the registering business and verifies the phone numbers. Post validation, registering companies receive actionable information as part of the free registration process. This includes the provision of any specific telephone lines which have been labeled as scam, summarization of numbers perceived as high nuisance and summarization of pre and post-categorization of numbers.

First Orion provides call transparency solutions through the T-Mobile mobile network, and through the PrivacyStar mobile app. PrivacyStar is one of the largest sources of complaints to the Federal Trade Commission. Users can simultaneously block calls and file a complaint with just a few clicks, directly from their mobile phone. This led to astronomical growth in complaints filed. In January 2012, when PrivacyStar had just started feeding complaints to the FTC, 389 complaints about debt collection were submitted through the app. In January 2016 that number was 74,800. In the same month, 6,800 debt collection complaints were processed by the CFPB.

insideARM Perspective

First Orion has been among the most cooperative call blocking/labeling providers, engaging with regulators and industry to address the problem of mislabeled calls. This is what led to the establishment of their CallTransparency portal. While other providers have also been at the table, none has released a similar tool or offered a defined path for communication with legitimate businesses. 

The ARM industry has worked to educate the wide range of organizations in this new ecosystem about the unique challenges faced by debt collectors related to potential third party disclosure associated with call labeling. One result of this is that First Orion adopted “account servicing” as a substitute label for debt collection. This willingness to compromise has been greatly appreciated. And…it’s clear — to me at least — that this is a temporary and imperfect solution. It’s not the full transparency that a consumer would want, and once it becomes known that “account servicing” is a moniker for “debt collection” it may end up carrying the same risk.

This is actually a perfect example of why the industry needs a change in regulatory approach related to third party disclosure. See my opinion post for more about this.

 

The District of Nevada, relying on the ACA International v. FCC decision, granted summary judgment in favor of The CBE Group, Inc. (“CBE”) on a TCPA claim. In Marshall v. CBE, the court found that CBE’s Manual Clicker Application (“MCA”) used by CBE is not an automatic telephone dialing system (“ATDS”). 

The decision (read it here) also discusses an FDCPA claim and procedural issues related to an expert opinion, but this article focuses solely on the TCPA facet of the case. 

Factual and Procedural Background

Plaintiff fell behind on her DirecTV bill, causing DirecTV to place the account with CBE for collection. CBE, through its skip-tracing vendor, obtained plaintiff’s cell phone number and began calling this number in its attempt to collect the debt. 

To place these calls, CBE used the Manual Clicker Application (“MCA”) created by CBE, which works in conjunction with LiveVox. Through MCA, a CBE agent places a call by clicking a bull’s-eye on the computer screen, which causes a call to pass through LiveVox’s cloud, and connects a CBE agent with the person to whom the call is placed.

Plaintiff filed a lawsuit against CBE alleging, among other things, that CBE violated the TCPA by using an ATDS to place calls to her cell phone without consent. The parties filed summary judgment motions. On the TCPA issue, the court granted summary judgment for CBE. 

The Decision 

The court, pursuant to the D.C. Circuit Court of Appeals’ decision in ACA International v. FCC, stated that it would apply the strict definition of an ATDS. Reviewing the facts with this in mind, the court found that the dialing system used by CBE is not an ATDS, thus finding that there is no TCPA liability for CBE.  

The court found that the MCA software used by CBE quantified as human intervention per the overwhelming case law authority on the issue, specifically since the agent had to physically point and click the bull’s-eye in order to initiate the call.  Plaintiff failed to present sufficient evidence to show that the MCA system can place calls on its own without human intervention.

The court discounted plaintiff’s expert witness’s opinion. One big issue pointed out by the court was that plaintiff’s expert witness did not actually view the system used by CBE. Instead, the expert used analysis of the technology found in court decisions. This, the court found, was insufficient for the expert to determine whether the specific system used by CBE was or was not an ATDS.

Similarly, the court dismissed plaintiff’s argument that somehow it is LiveVox, and not CBE, that placed the call. Plaintiff’s expert witness failed to persuade the court that that CBE’s call tracking report somehow shows that LiveVox places calls.  The court shut this argument down stating that “there is no evidence, or legal authority, suggesting that LiveVox’s ability to track calling information means that the system has the capacity to store or produce numbers to be called using a random or sequential number generator.”

Ultimately, the court found that the undisputed facts showed that CBE did not use an ATDS to place calls to plaintiff’s cell phone.

Analysis 

The ACA v. FCC decision is starting to bear fruit. By striking down the 2015 FCC Order, the D.C. Circuit Court of Appeals provided clarity on what constitutes an ATDS. Prior to this decision, the debt collection industry, which still heavily relies on placing calls to consumers, erred on the side of caution in order to avoid tripping TCPA liability, which is uncapped.

In the instant decision, it is apparent that the ACA v. FCC decision simplified the analysis for the court of what is and is not an ATDS. Rather than having to wade through the waters of the definition of “capacity,” the court was able to reach a well-reasoned, clear conclusion that the phone system used by CBE was not an ATDS.

ROCHESTER, N.Y. –– Continental Service Group, Inc., dba ConServe, a leader in the collections industry, announced today it has named Rich Klein as President. Effective immediately, the move is a strategic repositioning that will allow its CEO and former President, Mark E. Davitt, to focus on future growth opportunities for the company.

With more than 30 years as an innovator and role-model in the accounts receivable management field, ConServe will begin implementing an Accelerated Growth Plan that will provide a solid foundation for success for many years to come. This new initiative provides incredibly exciting opportunities to drive dramatic growth for ConServe and is something to which each and every member of the team will contribute. “We are extremely enthusiastic to launch this Accelerated Growth Plan at ConServe” says Rich Klein, ConServe’s newly-appointed President. He continues: “This effort will provide the means by which the ConServe team can continue exceeding our Clients performance and service expectations while reinforcing and aligning our organizational goals with our vision and objectives for the future.”

In his new role as President, Klein brings deep industry knowledge as an accomplished senior financial executive and well-rounded experience in all aspects of accounting and financial management. He has extensive professional experience among some of Rochester’s most dynamic companies, is a graduate of St. John Fisher College and the University of Rochester, William F. Simon School of Business, and is heralded as an ingenious and enterprising leader with keen insights. 

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Klein has had an influential role in positioning ConServe for the numerous recognitions they have received that include appearing on Inc. Magazine’s Inc. 5000 list of the fastest growing privately-owned companies in the nation (7 times), being named a Rochester Top 100 company (14 times), recognized as a Rochester Top Workplace (4 times), receiving the Better Business Bureau’s Torch Award for Ethics, receiving a Rochester Business Ethics Foundation ETHIE award, and being recognized by insideARM as a Best Place to Work in Collections/Best Call Center to Work For as part of an industry excellence program (5 times). His humanitarian priorities are exemplified by ConServe’s recognition by the Association of the Blind and Visually Impaired (ABVI) with their Community Partner Award and the Association of Fundraising Professionals- New York Genesee Valley Chapter’s Outstanding Corporation Award.

About ConServe

ConServe is a top-performing award-winning provider of accounts receivable management services specializing in customized recovery solutions in higher education, government, consumer and commercial markets. For over 30 years, we have been a consumer-centric organization that operates as an extension of our Client’s valued brand. Anchored with ethics and compliance, we’ve redefined collections with The ConServe Advantage® while partnering with our Clients to give them peace of mind and to help them achieve their goals. Ethics. Technology. Performance.

Put The ConServe Advantage® to work for you: www.conserve-arm.com

WOODLAND HILLS, Calif. – Account Control Technology Foundation (ACT Foundation), a non-profit, charitable foundation established by the founders of Account Control Technology Holdings, Inc., is now accepting applications for its annual scholarship programs, which provides $1,000 individual awards to students nationwide.

The ACT Foundation Second-Year Scholarship Program is for current college first-year students who plan to enroll as sophomores in a four-year college or university in the fall of 2018. A total of nine $1,000 scholarships will be awarded to students nationwide.

The ACT Cares Community Scholarship Program is for graduating high school seniors from specific communities who will attend a four-year college or university beginning in the fall of 2018. Applicants must be current seniors at high schools within select counties surrounding our ACT Holdings, Inc. offices. The locations and counties are as follows:

• Atlanta, GA: Fulton & DeKalb County
• Augusta, GA: Augusta-Richmond County, Columbia County, GA, Edgefield County, SC, Aiken County, SC
• Bakersfield, CA: Kern County
• Boca Raton, FL: Palm Beach County
• Dallas, TX: Dallas, Denton and Collin Counties
• Gainesville, VA: Prince William County
• Houston, TX: Harris County, Montgomery County and Fort Bend County
• Mason, OH: Butler, Clermont, Hamilton and Warren Counties
• Montgomery, AL: Montgomery County
• Peoria, IL: Peoria County
• Phoenix, AZ: Maricopa County
• Renton, WA: King County
• San Angelo, TX: Tom Green County
• San Antonio, TX: Bexar & Medina County
• White Plains, NY: Westchester County
• Woodland Hills, CA: Los Angeles County, Orange County 

A total of sixteen $1,000 scholarships will be awarded. 

The application deadline for both programs is May 1, 2018. The scholarship selection process will be administered independently by Scholarship America. Application guidelines are available at www.accountcontrolfoundation.org or for more information email actfoundation@scholarshipamerica.org.

In addition to providing information on its scholarship programs, the ACT Foundation website offers content and links to help students plan and pay for college, as well as gain tips to improve their financial wellness. 

About the ACT Foundation

The Account Control Technology Foundation is a charitable organization established by ACT Holding’s Founders, Dale and Debbie Van Dellen, with a stated mission “to improve the future of students and the greater community by offering financial literacy and debt management education, mentorship and support to those in need.” For more information email visit www.accountcontrolfoundation.org 

About Scholarship America

For nearly 60 years, Scholarship America has worked directly with students, parents, donors, colleges, businesses and communities to empower people to achieve their educational goals. As the nation’s largest private education support organization, having distributed over $3.7 billion to more than 2.3 million students, Scholarship America is now working to further engage the private sector to support programs and policies that advance equity in postsecondary education and help students overcome barriers to access, persistence and attainment. More information is available at www.scholarshipamerica.org.

POLITICO reported last week that, according to an internal memo it obtained, the Department of Education has announced some “organizational changes” at the Office of Federal Student Aid (FSA). James Manning, the acting head of FSA since January, announced the appointment of a new chief of staff and chief information officer. 

The new chief of staff will be Marianna O’Brien, who previously worked at the National Student Clearinghouse, The College Board and FSA. Colleen McGinnis, who had been serving as chief of staff for the past three years, will become FSA’s acting chief performance management officer.

The new FSA chief information officer will be John Fare, currently the chief performance management officer. Fare will replace current chief information officer Keith Wilson, who will become a senior adviser in business operations. In addition, Jeff Appel will become FSA’s director of policy liaison and implementation. Appel previously served as deputy undersecretary of education during the Obama administration.

POLITICO also reported that Manning’s email on Friday outlined plans to divide up oversight of the various units of FSA between himself and his deputy, Kathleen Smith. Under the new plan, FSA’s administrative functions — including acquisitions, finance, strategy and technology — will report to Manning. And the “operational business units” — which include enforcement and program compliance — will report to Smith.

FSA is the unit of ED that oversees the private collection agency contract which is currently embroiled in round two of litigation. Industry sources have been aware of personnel changes, but the Department has been tight-lipped about who is now responsible for decisions related to the unrestricted (large collection agency) contract. 

 

Acting CFPB Director Mick Mulvaney has released his first Semi-Annual Report to Congress. The period covered by this report, April 1, 2017-September 30, 2017, does not include his own time in the office. It is notably different than the reports submitted by his predecessor, Richard Cordray, as he includes recommendations to limit the power of the position he holds. In his opening message Mulvaney says,

“As has been evident since the enactment of the Dodd-Frank Act, the Bureau is far too powerful, and with precious little oversight of its activities. Per the statute, in the normal course the Bureau’s Director simultaneously serves in three roles: as a one-man legislature empowered to write rules to bind parties in new ways; as an executive officer subject to limited control by the President; and as an appellate judge presiding over the Bureau’s in-house court-like adjudications.”

He then makes the following recommendations:

1. Fund the Bureau through Congressional appropriations;
2. Require legislative approval of major Bureau rules;
3. Ensure that the Director answers to the President in the exercise of executive authority; and
4. Create an independent Inspector General for the Bureau.

You can download the full report here.

The report makes brief mention of debt collection rules, confirming that “the Bureau will work towards releasing a proposed rule concerning FDCPA collectors’ communications practices and consumer disclosures.” No estimated timing is provided.

Mulvaney is scheduled to testify to Congress next Wednesday, April 11, regarding his recommendations and his work so far at the Bureau.

Data has been a necessary risk for collection agencies: keeping it on hand is an absolute must for confirming that you’re speaking to the right consumer; however, having it stored, especially electronically, opens you up to the possibility of a data breach.

As Greg Toler of Cornerstone Support writes, “Cyber liability and network security coverage is a constantly evolving, and often confusing, form of insurance, but a necessary part of every collector’s commercial insurance policy line-up.”

Recently, during a Compliance Professionals Forum monthly peer call, members discussed how long companies were keeping consumer data on hand. In response to the question, “Why not just hold all data essentially forever?” one caller said, “The reason we want to purge as soon as possible has to do with insurance: the more records you have the more it costs to insure.”

Other factors affecting the cost of cyberinsurance include company revenues and loss history. However, things like strong controls around network access and robust security protocols can help reduce some cyberinsurnace costs.

This FAQ recently published by Cornerstone answers the question, What coverages should be on my policy?

Notification Costs
Breach notification cost, sometimes referred to as event management, is the limit of insurance designated to consumer notification in the event of a breach. Forty-eight states and some United States territories have enacted legislation requiring private entities to notify consumers of security breaches when their personally identifiable information is at risk. State laws typically define compliance expectations and what is considered a breach. Often, written and mailed notification is required, which can be a large percentage of the costs paid by the carrier. Based on the number of individual’s records stored, notification costs alone can be a major expense.

Cyber Extortion
Cyber extortion is the act of demanding payment by threat of data compromise, system lockdown, or other threats requiring a ransom. Cyber extortion has become more common, and often triggers multiple forms of coverage. Extortion coverage is the specific limit designed to pay demands and ransom.

Business Interruption
Business interruption limits cover the loss of income and operations expenses when interrupted or suspended due to a breach of network security. For example, if an extortionist holds your system for ransom and you can’t conduct business or your system is shut down while trying to repair damage from a hack or virus, the business interruption limit would cover the lost income. Business Owners Policies (BOP) do often include a supplemental limit for business interruption costs, but most BOP’s exclude business interruption claims arising from a network security event.

Regulatory/PCI fines coverage
Specific limits can help cover the costs of dealing with state and federal regulatory agencies which oversee data breach laws and regulations. Costs can include defense, penalties, and fines due to regulatory and PCI compliance violations.

Cyber Crimes
Cyber crime coverage includes limits to indemnify funds lost through email phishing, telephone fraud, fraudulent instructions, or anything dealing with the voluntary transfer of funds due to a scam. Some policies will exclude or sublimit cyber crimes which may help with premium costs. Generally, this coverage is not included on a standard crime/theft policy.