Don’t Get Spooked by Government Requirements

Scary Jackolantern

Use These 3 Steps to Effectively Support Your Compliance Program

Friday is Halloween, the time of year for jack o’lanterns, haunted houses and horror films. Kids are looking forward to free candy, and adults are planning ways to scare one another silly. As I was picking out my costume this year, I got to thinking about the different things that scare us.

In the collections industry that I serve, one of the scariest things imaginable is an audit by the Consumer Financial Protection Bureau (CFPB). Unlike a harmless Halloween trick, a CFPB audit is serious business, and can result in fines and penalties that can have a chilling effect on a collections agency.
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Luckily, your organization doesn’t have to be spooked by the compliance requirements from the CFPB or other regulatory bodies. With proper planning and processes in place, you can establish and monitor your compliance efforts to ensure you are prepared should your company be subject to an examination.

The cornerstone of your program is a well-documented, well-communicated compliance plan. This is the roadmap for your good faith efforts. You’ve got to have one, and there are many available resources to guide you in designing one suited for your organization.
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But – having a compliance plan by itself is like a cheap ghost costume without eye holes. Like a sheet, it covers you, but you can’t see where you’re going. It’s not enough to put your expectations in a document or merely tell your team what you expect from them, you must have a means of monitoring staff conformity to the rules and procedures you’ve outlined in your plan.

Here are 3 steps that will enable you to effectively support and maintain your compliance program:

If you’re to have a ghost of a chance at effectively monitoring agent activities and script compliance you’ll need the ability to review and analyze every single call. Manually spot checking or using a tool that enables you to screen only a portion of the calls your collectors make each month isn’t sufficient. If you can’t assess what’s happening across 100 percent of your interactions, you could miss that small percentage of calls where your agent Dr. Jekyll becomes Mr. Hyde and goes off script to harass a customer. That’s an extreme example of course, but even a series of smaller infractions can put you at risk of fines. Random call sampling won’t provide the level of oversight needed to keep you safe in the event of an audit. You can’t defend that as a reliable compliance plan.

So, once you have a handle on what is taking place during any and all of your calls, you’re in a position to take action to correct any deficiencies you may find – or spread best techniques from any superstar agents across the rest of your team. You’ll know if individual agents require coaching to address specific shortcomings, or whether some aspect of previous training didn’t seem to stick with the team. You can create a specific plan of action on an individual agent level, rather than subjecting the entire team to repetitious training that may be unnecessary.
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Unlike Halloween which only comes once a year, ensuring your collection center’s compliance is a 365-day affair. You monitor calls, discover concerns, take action to correct the problems and trend the results of your efforts over time. Continuing to listen to 100% of your collections calls will tell you if your training or coaching was effective, and it can help you determine which types of interventions seem to have the most beneficial effect. Even the best instruction can be lost during a daily routine, so vigilance is required to ensure best practices and desired agent behavior sticks.
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Follow these steps and you’ll be successfully supporting your compliance plan. You’ll rest in peace knowing you don’t have to be haunted by the prospect of a time-consuming and distracting government audit.

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