How ERC is getting their team and clients prepared for November 30th
SVP, Client Solutions
Reg F is arguably one of the biggest changes to the ARM industry since
the inception of the FDCPA. What is ERC doing to ensure compliance with
all the changes in Reg F?
SVP, Legal and Compliance
The first thing that ERC chose to do is to prioritize. We shifted all the focus
on prioritizing those things that would make us jump in and immediately
engage the client. The biggest thing has been collaboration, not just internally with all the different departments, but also making sure everybody
understands what’s expected and how to get to that end goal of being
compliant under the new reg. We’ve also collaborated with clients to make
sure that they’re educated, know what to expect, and how to prioritize
things on their end as well.
KP: How is ERC leveraging technology to ensure compliance with all the Reg F changes?
SG: I think that the greatest thing that came from Reg F is the shift from that archaic stance of phone calls just from the agent to the consumers and land lines and mailing physical letters. Obviously, we’ve taken a giant leap into technology, and Reg F has allowed us to take that leap as well. Leveraging the technology means adjusting the way that we communicate, and it’s allowed us to open the doors to look at email communications. I think the biggest hurdle that we’ve had is trying to help our clients understand that their consumers really do prefer to be communicated with via email, or via text message. Really, if we look at it, how often do we get excited to pick up the phone anymore?
KP: How do you think Reg F is going to change collection communication practices going
SG: Consumer-driven communication is key. Certainly, normal agents and collection agencies are going to have to be the ones to initiate that communication. The change there will allow the consumer to tell us, how they want us to talk to them. When do they want us to talk to them? I think that the biggest change in the communication preferences is not really going to be necessarily the actual medium of communication itself.
KP: How do you think these changes will impact our industry on November 30th?
SG: We’re all anticipating this big onslaught of crazy, and we just want to get it right. November 30th is going to turn around and we’re going to look at our stuff and say, this is great. We have a lot more means to communicate with our consumers, and the experience has taken a shift overall. We have a much better relationship development with our clients, and they’ve learned that we’re doing a great job and we’re helping them as well as their consumers.
KP: What are some of the benefits that clients will have with sending the handshake letter to
pass on consent to their agency network?
SG: This is a new thing for clients. Even the concept of giving a heads up to a consumer that their account is going to go to an agency seems so foreign, and maybe even a little uncomfortable. There was some trial with handshake letters just with a couple of agencies and one creditor with the CRSD under inside ARM. In that trial, it was found that collections increased quite a bit. Complaints were driven down, and that’s a massive win, not just for clients, but also for consumers. So, the overall result of that could only be good. You’re going to see a decrease in overall consumer complaints related specifically with not knowing that the account went to collections, and you’re going to see an increase in actual dollars collected.
KP: How can ERC and its clients thrive in a Reg F environment?
SG: I think that if clients and agencies continue to communicate and collaborate as we start to come up with different, either expected or unexpected hurdles, we can attack those things together. I think we’re going to find that the biggest win out of all of this is going to be the newly developed relationship with trying to tackle some of those common issues that we’ve
always faced, but either had to tackle by ourselves or on behalf of the other. I think that agreeing to put the consumer first and in the driver’s seat is a win.
KP: Seven calls in seven days. How do you think this is going to impact ERC’s performance and productivity?
SG: It’s no secret that there’s going to be some impact. ERC has chosen to take the conservative approach, which I think is appropriate. We want to make sure that we’re being careful and thoughtful about how we are implementing our new processes. We’ve restricted how often, on all fronts, we’re able to communicate with the consumer within a day because we want to make sure that, one, we’re not crossing any lines that might come off as irritable. Two, we don’t want to raise red flags. And lastly, we also don’t want to upset the consumer; that doesn’t benefit anybody.
KP: ERC is in the home stretch. What does this last month of preparation look like?
SG: We have put in place our model B form. We think it looks exactly the way our clients want it to look. We are now looking at all the different systemic changes and making sure that those are well aligned. The biggest piece right now is training. Now, Agents must ask more probing questions. Questions like, “when is a good time for us to contact you?” That has not generally been the practice. I think our biggest focus would definitely be setting our Agents up to be very successful with all the new roles.