Collector - March 2017 - 31


them into your business processes and
communicate them to employees.
While the CFPB recognizes there is
no one-size-fits-all formula for creating a
CMS, it has regularly communicated that
an effective system should incorporate four
essential principles:
* Board of directors and management
oversight;
* A compliance program (consisting
of policies and procedures,
training, monitoring and corrective
action);
* A system to manage consumer
complaints; and
* A compliance audit.
Of course, you'll need to set realistic
expectations for your processes depending
on the nature and size of your business.
Larger companies naturally have more
capacity for immediate change than
smaller companies, which may be wary of
embarking on time-intensive and expensive
compliance projects.
If your company's small staff size and
limited resources make strengthening your
CMS seem overwhelming, concentrating
on the highest-risk areas with the most
consumer interaction is a good place to
start. Getting an effective CMS tailored to
your business is really just a matter of being
disciplined enough to manage a project from
start to finish.
"Instead of having 20 projects on your
plate, really narrow your focus to just five
or six initiatives each year," said April
Lindauer, chief compliance officer for I.Q.
Data International. "That will not only help
you focus on those initiatives in a reasonable
time period, but could also help you get buyin from the rest of the company."

KEEP EVERYONE IN THE LOOP
Set aside time to regularly update your
senior management on the company's
current compliance initiatives and latest
risk assessment results. Schedule these

COLLECTOR 03.17

G73656ACAI.indd 31

meetings at a pace that fits your company-
monthly or at least quarterly would
probably be the most helpful.
"It's really important to meet and decide
what you need to focus on in terms of
projects or initiatives-not only from a
compliance perspective, but also in terms of
how the business can support compliance
projects as well," Lindauer said. "Regular
meetings help you make sure you are
level-setting on a periodic basis about
what's going on in the industry and with
your compliance projects. It can help you
prioritize and keep the dialogue open."
Company executives should back up
their CMS not only with financial resources
(spent on compliance projects as well as
compliance-based compensation incentives),
but also by embodying the principles and
values of continuous improvement.
Give your compliance staff member
or team a seat at the table for all business
decisions. If your staff isn't fully plugged into
your CMS, they may be making decisions
that conflict with it or that would simply
benefit from a quick compliance review.
"Often a seemingly small decision is made
and isn't vetted appropriately for compliance
risks, and the next thing you know you are
facing consumer litigation or regulatory
scrutiny," said Alexandra Megaris Esq.,
counsel at Venable LLP.
It's just as important to maintain an
ongoing dialogue about compliance with
your frontline collectors. What are the dayto-day challenges they're facing right now?
Focusing on their challenges and habits
can help you make cultural enhancements
related to your specific compliance culture.
"When you look at it from the bottom
up, you can take the focus away from it
being an edict coming from on high and
ideally achieve buy-in from individual
business units and employees at all levels,"
Pompan said.
Make sure all your employees know how
to access the most current versions of your

"It's important to
maintain an ongoing
dialogue about
compliance with your
frontline collectors.
What are the day-today challenges they're
facing right now?"

31

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Table of Contents for the Digital Edition of Collector - March 2017

Collector - March 2017 - Cover1
Collector - March 2017 - Cover2
Collector - March 2017 - 1
Collector - March 2017 - 2
Collector - March 2017 - 3
Collector - March 2017 - 4
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