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Know the Most Important Sentence in Lardner

By: Rip Harris | August 29, 2014

In the same way Nelson v. Santander [later vacated] elevated “present capacity” to the forefront of TCPA analysis, the recent case of Lardner v. Diversified Consultants, Inc., decided April 20, 2014, raises “store” as the TCPA issue du jour. In Lardner, the defendant collection agency came under fire after plaintiff Angela Lardner filed a lawsuit claiming her cell phone had received as many as 126 calls that were in campaign mode or a manual blend mode, which is a mode where the collector either manually enters a number or uses the campaign mode
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#6 - Ask for a Data Dump

By: Rozanne Andersen | August 27, 2014

Survey results only go so far. They provide you with an idea of what your partners have done, but not what they are currently doing by way of compliance. You will want to consider asking them to provide materials that support their assertions. In order to truly understand the risks posed by any service provider and their ability to comply with federal consumer financial laws, you may want to have them explain their policies, procedures, internal controls, and training materials as such relate specifically to compliance with consumer financial laws. This information will serve as a window into the service provider’s organization, and help you determine whether they conduct training and manage their employees who have consumer contact, or contact with consumer data.
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2 Magic IT Onboarding Steps can Yield Amazing Efficiency Gains for New Staff

By: Greg Hensley | August 25, 2014

Onboarding can be a real issue for high-volume receivables operations, and stressful for IT organizations to manage initially. How do you take 2 steps forward without taking 1.99 back?
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#5 - Survey and Categorize by Risk

By: Rozanne Andersen | August 19, 2014

Constructing an adequate instrument to determine risk is one of the biggest challenges inherent in developing an effective vendor and service provider oversight program. That’s why it’s the best first hurdle to leap once you have your program in place. At the outset of your business relationship, and at least annually thereafter, survey your service providers to determine the level of risk of consumer harm each one poses to your consumers, the clients you serve, and the data you must protect. The service provider community is accustomed to receiving these sorts of survey requests, and many have completed, self-certified surveys on hand for that purpose.
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#4 - Launch Your Due Diligence Process Regardless of Your Size

By: Rozanne Andersen | August 12, 2014

Contrary to popular opinion, no matter your size, you’re responsible for having a concrete, documented system to ensure you’re watching over your vendors and service providers. The law requires it. If you are a Larger Market Participant debt collector, debt buyer, or collection law firm, you fall under the direct supervision of the CFPB. As such, you must have a robust and meaningful service provider management program in place. The CFPB will include service provider management in its examination of your organization, and hold you accountable for its requirements. For those of you who are service providers, pay special attention to the fact the CFPB also has the power and authority to supervise you if you are a service provider of supervised organizations and Larger Market Participants.
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The Top 5 Reasons to Attend #PowerUp2014

By: Casey Stanley | August 6, 2014

For many ARM and healthcare receivables professionals, PowerUp – the annual Ontario Systems customer education and user conference – is the most valuable industry event they attend all year. Last year featured surprising discussion about technology as a whole, major announcements about our company and products, and dozens of sessions, workshops, and presentations covering everything from operations, to compliance, to industry trends and trajectories. This year, we plan to up the ante even more. Here are five big reasons why you need to be in Indianapolis this October:
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#3 - Take Inventory

By: Rozanne Andersen | August 5, 2014

Perhaps the easiest way to judge the size of your program, and its required resources, is by quantifying the number of pieces it involves. Who exactly are your vendors and service providers? You can’t manage what you don’t know. Create a list of every service provider with which you have a business relationship, and which supports your core collection business in any way. Remember to include any business that touches, transmits, houses, or has access to consumer financial information on this list. You may refer to this document as your Service Provider Inventory. An Excel spreadsheet would work well for this purpose.
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Talk More, Hold Less: 3 Common Reasons Why Agencies Miss Calls, and How to Recover Them

By: Steve Stone | July 31, 2014

We’ve talked before about two types of inbound calls: The ones picked up by agents, and the ones we miss. You can guess which is preferable – But how do you raise its numbers? Knowing how many calls you’ve missed is only the tip of the analytical iceberg. To begin learning how to raise connections with agents, you need to start by examining how many inbound calls occur during normal business hours, and how many occur before and after. Chart the total number of inbound calls by hour for an entire month, and then overlay your “normal business hours.” What do you see? Do most inbound calls come in during those hours? Is there a huge dip before and after? There should be – Otherwise you might need to reevaluate your staffing needs, or add additional technology to handle the volume.
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#2 - Establish Your Vendor and Service Provider Oversight Team

By: Rozanne Andersen | July 29, 2014

Effective oversight, across any function, is a group effort – not the work of a single executive or manager. That’s why it’s best to establish a group tasked specifically with overseeing their activities. Ongoing monitoring is an essential component of your Service Provider Oversight Program, and extends throughout the duration of the business relationship. After entering into a contract with a service provider, senior management should dedicate sufficient staff with the necessary expertise, authority and accountability to oversee and monitor your service providers. As you select members of your staff to oversee your service provider management program, make sure you select individuals whose experience and authority is commensurate with the risk and complexity of the service provided by the third party.
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#1 - Start With the Basics: Definitions

By: Rozanne Andersen | July 22, 2014

Let’s start your path to effective vendor and service provider oversight with perhaps the toughest step: getting everyone on the same page. Compliance relies on consistent communication across your entire enterprise. Never interesting - but always important to the foundation of any project - is a thorough understanding of terms. Many projects have been thwarted by misaligned team members speaking different languages. A solid vendor and service provider management program must be built using consistent definitions, common themes, and well-articulated goals. Third-Party Service Provider [general]: Understanding who must be managed is the first order of business. The CFPB and the OCC use the term service provider to describe a business with which your organization has an established business relationship by contract or other agreement. Sometimes the term vendor is used interchangeably with the term service provider. However, be aware the CFPB does not expect you to manage all of your business relationships with the same degree of oversight.

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