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Update: Reminder on Communication Procedures During Severe Weather Emergencies

communication procedures ACA members have strong systems in place to ensure compliant communications with consumers who are impacted by a natural disaster or state of emergency. Here’s a rundown of what you should keep in mind and available resources, including a key ACA SearchPoint document and news on North Carolina’s state of emergency as well as a consumer guide from the CFPB.

09/30/2022 3:30 P.M.

2.5 minute read

Several areas in the U.S. have declared a state of emergency as Florida’s Hurricane Ian continues to impact North Carolina, South Carolina, Virginia and Georgia.

Since the storm hit, North Carolina’s Gov. Roy Cooper declared a state of emergency.  The North Carolina Department of Insurance’s Omnibus Bill signed into law earlier this year includes some limits for debt collection calls during a state of emergency.

Except as provided in subsection (c) of Section 10 of the law, collection agencies shall discontinue attempts to collect debt against their customers who reside within the designated area in the proclamation or declaration during the deferral period.

ACA International members have strong compliance management systems in place to manage calls and modify consumer outreach strategies to consumers in areas affected by the hurricane or where do-not-call orders are in effect.

Much like during the COVID-19 pandemic, members can implement hardship programs to limit calls to consumers and/or set up payment plans to help them manage their accounts when communications resume.

ACA encourages members to use their judgment and discretion when contacting consumers who may be impacted by the state of emergency at this time and consult with their counsel for guidance if needed.

As the hurricane and its impacts continue, ACA members should review their communication plans to help consumers impacted by a natural disaster, as well as their business preparedness strategy.

ACA Resources for Businesses and Consumers

ACA encourages member companies to update their disaster preparedness plan in the case of emergencies like those that occurred in Florida and neighboring states.

Disaster preparedness is twofold in the accounts receivable management industry—members must have plans in place to protect their companies and employees and there must be a plan for modifying communications with consumers who may be affected by a weather emergency and cannot make a payment or be reached by telephone or mail, temporarily, ACA previously reported.

Alliance ACA partner Agility Recovery also offers resources to aid member companies in emergency preparedness, including through a National Preparedness Month kit.

Federal resources are being allocated to areas affected by the hurricane, which members can also share with consumers as appropriate.

Consumer Financial Protection Bureau Financial Toolkit

The Consumer Financial Protection Bureau is offering a guide for consumers with suggestions on how to handle their finances during a disaster or emergency.

Within the guide are resources to help consumers recover, such as tackling housing issues, protecting finances during an emergency, dealing with property damage and managing bills. The bureau also shares tips if you are helping others rebuild, including ways to safely send money through mobile apps.

The CFPB also offers a list of resources from the Federal Emergency Management Agency and the American Red Cross, among others.

Internal Revenue Service Tax Relief

Those affected by the hurricane will have until Feb. 15, 2023, to file various individual and business tax returns and make tax payments.

The IRS is offering relief to any area designated by the Federal Emergency Management Agency (FEMA). This means that individuals and households that reside or have a business anywhere in the state of Florida qualify for tax relief. The current list of eligible localities is always available on the disaster relief page on IRS.gov.

The tax relief postpones various tax filing and payment deadlines that occurred starting on Sept. 23, 2022. As a result, affected individuals and businesses will have until Feb. 15, 2023, to file returns and pay any taxes that were originally due during this period.

Emergency Communications

The Federal Communications Commission has made available emergency communications needs 24 hours a day, 7 days a week in relation to the effects of the storm and urges emergency communications providers to contact the FCC Operations Center for assistance.

Additionally, the FCC has released procedures for providing emergency communications in Florida counties impacted by the hurricane, with guidance on special temporary authority (STA) for wireless telecommunications and other needs in the aftermath of the storms.

For more compliance information, visit ACA’s SearchPoint Library, which includes a document on Natural Disasters & Collection Efforts for members.

If you have executive leadership updates or other member news to share with ACA, contact our communications department at [email protected]. View our publications page for more information and our news submission guidelines here.

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