Reflecting on Reg F

How an ACA member company prepared for Reg F and plans to use its training and education for collectors moving forward.

11/30/2021 2:00 PM

4.5 minute read

 

By Tony Palmer

The Nov. 30 date we all circled on the calendar a few months ago has certainly snuck up on us. It’s hard to believe we’re already a couple of days beyond the effective date for Reg F.

It seems like yesterday we were all at ACA International’s annual convention in Las Vegas with so many questions that had not been answered.

Accounts receivable management industry veterans like John Bedard and many others devoted countless hours to research and webinars. We checked our inboxes multiple times a day for the latest updates and lined up our questions for every online seminar we could attend in hopes they would get answered. I was on one online seminar where 74 questions were submitted before it started, with many more coming in during the presentation. There is a lot of information within that wordy regulation, with much of Reg F not being clear to even the sharpest legal minds.

Now Reg F is upon us, and many of us have gone to great lengths to make changes to comply.

I would like to briefly review a couple of steps we took at our agency in the hopes they may help other ARM industry professionals as you continue to review your Reg F compliance plans.

Itemization Date Questions

Our first step was to answer many of the questions about the itemization date our clients should select. We went back and forth on some simple questions before tackling more complex topics and contacting all our clients to fill them in about Reg F. Once we had a good understanding of exactly what our clients would need to provide to us prior to Nov. 30, we started the process of educating them about Reg F.

This proved to be a challenge with staffing already difficult due to COVID-19 issues and larger staff shortages seen within the ARM industry and for its clients. We started to slowly reach out to clients and gradually became more diligent in our attempts by letting them know we would not be able to load accounts come Nov. 30 without the proper information. We dreaded these calls, but to our pleasant surprise all of our clients were prepared because they know and understand government regulation all too well. We have already secured our clients’ choice of the itemization date and the transactions that will follow that date. We were also able to update our client profiles with that data and feel that in the first quarter of the game, we have all the pieces together.

Once we determined our clients’ preferences, we were able to get a couple of test files together to run a sample file with our letters. We wanted to ensure that all the data came over properly and that there would be no surprises. We also wanted to ensure our letters mirrored the letters that provide safe harbor under Reg F.

Consumer Communications

The next area we tackled was for the 7x7x7 rule. It seems most of us use collection software that utilizes short codes and action codes to navigate through the collection cycle. Ours will date the account to come back up on our collectors depending on what code they put into the system. We spent time figuring out the perfect science that would ensure it would not put collectors in a situation where they could make too many contact attempts. This no doubt lengthens the cycle as we will not be able to work through our flowchart as quickly as we could in the past. However, I am always trying to find a positive in every

situation and here this may allow a consumer have a little more time for challenges in their life to calm down. We have for many years worked accounts in phases for this reason. Now the phases are just a little bit more spread out, which may give the consumer a more time to resolve their debt.

Learn and Repeat

The last piece of the puzzle is one that we never stop trying to play— continuously educating our staff. We use Knowledge Link for so many trainings and plan to use it for Reg F on an ongoing basis. If you have never investigated this product, I suggest trying it. They allow you to create tests and even have questions come up at collectors’ workstations randomly for you to gauge their retention of key information. We have also had breakout sessions with collectors to train them on a specific area of Reg F. We ask all collectors to listen to each other and hold each other accountable.

ARM industry communications and education have also been a helpful tool in our Reg F preparation. ACA has done a wonderful job in putting together education and Reg F resources that connect us with the answers and information we need, as well as providing staff to help answer questions. The beginning of December will come and go just like it does every year. We are strong as an industry, and we will get through this hurdle and any others that comes our way.

Tony Palmer is COO of Alliance Collection Service and a member of ACA International’s Education Council.

For more resources on Reg F, visit ACA’s online Reg F Resource Center.

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