ACA members provide best practices for preparing compliant policies for electronic communications and working with vendor partners. The ACA Huddle series on part two of the rule continues through Jan. 15. Editor’s note: This article is available for members only.
1/12/2021 15:00
Change can be good. When there is time to implement changes, it’s a win-win—especially for accounts receivable management companies reviewing or establishing electronic communications policies before the Consumer Financial Protection Bureau’s final debt collection rule takes effect.
With change there can be challenges, however, according to Tuesday’s ACA Huddle speakers Jessica Klander, shareholder at Bassford Remele, Rob Augg, vice president of business development and marketing at Renkim Corp., and Paul Daniels, chief revenue officer of Intelligent Contacts Inc.
They reviewed delivery requirements and electronic communication requirements in the rule from a vendor’s perspective.
The CFPB’s final debt collection rule provides increased flexibility and guidance on how to contact consumers in person, by telephone, mail, or using electronic messages, according to the presentation.
Are you just getting started on electronic communications?
During the ACA Huddle, which is part of the series on part two of the CFPB’s final debt collection rule, the speakers reviewed tips to prepare communication strategies and plan with vendor partners and counsel to build processes and scripts.
The groups stressed there are more options to communicate with consumers, like email and text messages, but members need to make sure they receive consumers’ consent to use those methods and document proof of that consent.
Collection agencies working with a vendor partner should make sure they track consumers’ preferences and opt-out notices, for example. Do not rely on vendor partners to be the only keepers on this information. In the event the agency and vendor decide to stop working together or a contract ends, it’s best if all parties have the account information.
Klander, Augg and Daniels also revisited the validation notice requirements for electronic communications covered earlier in the ACA Huddle series as well as steps for tracking, securing and storing data on electronic communications for a consumer’s account.
Overall, the speakers stressed that it’s more important than ever for collection agencies to make sure their vendor partners understand their business.
ACA Huddle CFPB Rule Series Webinars Continue
ACA’s panel of experts continues to review the comprehensive rule and will be providing detailed analysis and compliance resources throughout this series of complimentary webinars, which continue through Jan. 15. Log on to acainternational.org and select My ACA to subscribe to Member Alerts under email subscriptions
On Wednesday, Jan. 13, James R. Bedell, general counsel at AscensionPoint Recovery Services LLC (APRS), Jack Brown III, president of Gulf Coast Collection Bureau, Inc., and Heath Morgan, partner at Malone Frost Martin, will weigh in on the topic of decedent debt.
On Thursday, Jan. 14, Tamar Yudenfreund, senior director, public policy at Encore Capital Group, and David Schultz, partner at Hinshaw & Culbertson LLP, will discuss time-barred debt.
Read more on all the upcoming webinars and register here.
ACA members can also download the ACA Mobile app for reminders on the upcoming ACA Huddle webinars and listen to the presentations, live or recorded, on the go.
Thank you to the sponsors of the ACA Huddle CFPB Rule Series, Neustar and Ontario Systems.
Related Content from ACA International
ACA Huddle CFPB Rule Series Part Two: Now is the Time to Think About Electronic Communications
Member Alert: Reviewing the CFPB’s Latest Amendments to Regulation F
Communicate and Create: Tips to Operationalize the CFPB’s Debt Collection Rule