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Like any business, ARM agencies start on a path to improved performance by measuring KPIs that define success. Traditionally, that’s meant a tight focus on the bottom line: Managers and executives tend to look at agents and ask first and foremost how many calls they’re making, and what the result from those calls have been. They use a scorecard that examines productivity, and dollars collected/promised, and they pay their agents on a bonus structure according to that performance. It’s a formula that’s worked for decades.

2015 Cost of Compliance ReportBut of course it’s in this more compliance-heavy environment that the Consumer Financial Protection Bureau (CFPB) has become a major actor. The CFPB’s primary goal is to ensure the consumer isn’t harmed by the tactics you’re measuring. So in this day and age, auditing your call center, and getting a grip on how your agents are working is just as important as how hard they’re working.

Ask yourself a simple question: If you have a bonus structure built entirely on calls made and dollars promised, how can you prove you’re not causing your agents to go against fair debt collection practices? Most agencies have a scorecard they use to make that determination, but in 2017 those practices aren’t sufficient. At the end of the day, you’re measuring your workforce based on dollars – And that tends to encourage a less-than customer-focused approach.

To be clear, we’re discussing the addition of a compliance score that measures side-by-side with your revenue goals, making it easy to show the CFPB, when they approach, how compliance is a baked-in part of your operation and culture. To some, that might seem like a superfluous task – But more than ever, compliance is crucial to your success and profitability. It can be very difficult to incent performance while discouraging non-compliance, on top of the fact that finding the right calls to drive margins can be difficult.

But even though it might seem difficult, at a basic level really comes down to three factors:

  1. How are you ensuring broad compliance?
  2. Are you watching your agents to determine whether they’re using abusive language?
  3. Can you prove your staff is treating consumers fairly within the CFPB’s definition?

Technology, and established and written policies and procedures are your tools to meet the challenge. Take the time to listen to a handful of calls, and score them according to the compliance controls you’ve already established. Just a quick glance at the way your agents are performing today can give you an idea of the broader issues in play within your operation, even if you don’t have a solution in place to determine the exact degree of compliance at which your agency is operating.

Compliance is a crucial factor when it comes to meaningful revenue recovery in 2017. And while compliance goals and production goals might often find themselves at odds, auditing your call center and adjusting your operations to make sure they operate in harmony should be a paramount objective as your business continues to grow.


Disclaimer: Ontario Systems is a technology company and provides this blog article solely for general informational and marketing purposes. You should not rely on the content of this material for any other purpose or as specific guidance for your company. Ontario Systems’ advice, services, tools and products described herein do not guarantee compliance with any law or industry standard. You are ultimately responsible for your own company’s actions and compliance efforts. Because everyone’s situation is different, you must consult your own attorneys, accountants, and/or other advisors to obtain specific advice on your company’s compliance, legal, tax, regulatory and/or other business needs. Despite Ontario Systems’ efforts to provide current and up-to-date information, you need to recognize that the information contained herein may become outdated quickly and may contain errors and/or other inaccuracies. 

© 2017 Ontario Systems, LLC. All rights reserved. Information contained in this document is subject to change. Reproduction of this publication is not permitted without the express permission of Ontario Systems, LLC.

About the Author

Chris Miller is an Ontario Systems Solutions Consultant with ten years of experience at the company, providing technical demonstrations and solutions to prospects and clients. Chris has worked with multiple agencies across the industry with a background that includes solution development, leading Artiva and other OS product implementations, collaborating with product development, business analytics, business intelligence, operations consulting and assisting with technical sales support and product demonstrations. Chris has a degree in Business Management Systems from Taylor University and an MBA from Anderson University.

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