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#9 - Remember UDAAP

By: Rozanne Andersen | September 18, 2014

The contracts you set can’t guarantee a perfect, incident free relationship. But they can help you manage risks that are difficult to identify and quantify. That’s why it’s important to pay particular attention to the requirements under the Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) section of the Consumer Protection Act. Historically, banks, credit grantors, and members of the credit and collection industry have been under the mistaken belief that once they outsource a service to a service provider they have washed their hands of responsibility. Make no mistake: Those days are long gone. The CFPB and other federal banking regulators expect banks, credit grantors, and members of the credit and collection industry to practice effective risk management regardless of whether the organization performs the activity internally or through a third party. Your use of a third-party service provider does not diminish the responsibility of your board of directors and senior management to ensure the activities performed by your service providers are done so in a safe and sound manner, and in compliance with all applicable laws, which may include UDAAP.
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2014’s Midyear ARM Review: The 5 Big Highlights

By: Rozanne Andersen | September 16, 2014

Evidence is clear: Those in the ARM industry who are adapting and investing in the “new world order” of increased regulation and government oversight are positioned to reap rewards. But how exactly?
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Flex Your Work Environment for Higher Engagement, Retention, and Productivity

By: Jill Lehman | September 11, 2014

Engagement, retention and productivity among employees are three of an HR pro’s most important goals. We take a lot of steps to bolster them, mostly in an effort to offer employees better compensation, in alignment with company goals and the bottom line, of course. But what if all three could be raised by changing the environment in which employees work? The truth is, big steps toward achieving all three can be reached in one fell swoop with a more flexible work environment – That is, giving your staff more control over their work time and schedules. That might be a scary thought, but I assure you, for many businesses the advantages of the practice outweigh the drawbacks. Workplace flexibility makes the most sense for executives who believe in three principles: Creativity, innovative spirit, and quality are more important than location Associates need to be energized, engaged and successful both at work and at home Energy leads to improved morale, increased productivity, better service, and reduced turnover
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#8 - Plan a Trip, Pay a Visit

By: Rozanne Andersen | September 10, 2014

Take the time to meet face-to-face with your vendors and service providers and see their operation in action. You need not treat all service providers alike. Tailor your oversight program regarding compliance with consumer financial and data security laws to the risks posed by each of your service providers. A one size fits all approach is not necessary or even appropriate.
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#7 - Lock Down Your Vendor and Service Provider Contracts

By: Rozanne Andersen | September 4, 2014

Ensuring your vendors and service providers adhere to compliance expectations with regard to consumer financial laws and data security requires a binding, legal agreement. Once you select a vendor or service provider, you should negotiate a contract that clearly specifies the rights and responsibilities of each party. Include in the contract with the service provider clear expectations about compliance, as well as appropriate and enforceable consequences for violating any applicable compliance-related responsibilities, including engaging in unfair, deceptive or abusive acts or practices. Senior management may even want to obtain board approval of the contract before its execution when a third-party relationship will involve critical activities.
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The 7 Topics Healthcare Pros Will Hear About at #PowerUp2014

By: Steve Scibetta | September 3, 2014

No matter how many hours you put in at the office, ever-expanding data volumes, a murky trajectory for coding, and rapidly evolving regulation make the old ways of working healthcare receivables an uphill climb. Our mantra for the past year has been Work Smarter – Not Harder. And we’re excited to share some of the solutions we’ve developed at this year’s PowerUp 2014 event: The Ontario Systems receivables education and customer conference.
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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 “storage” as the TCPA issue du jour. According to court records in the Lardner case, 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 (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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