Collector - May 2017 - 17
websites to include a self-service option for
complaints. A recent survey found they were
twice as likely as other generations to take
their complaints online.
Convergent put this option on the front
page of its consumer site in 2015 but,
contrary to what you might think, the
company has actually seen a decrease in
consumer complaints since it retooled its
"Last year we saw a significant drop in the
number of complaints we received because
consumers came to our site and were able
to self-service and accomplish what they
wanted to accomplish, whether it was to stop
the calls or change their contact preference,"
In other words, consumers who feel like
they have some measure of control over an
often-stressful situation, who can easily find
answers to their questions and make direct
requests, are less likely to complain-to you
or to a regulator.
Not only do consumers want to feel in
control of the debt collection process, but
they also want to manage how you reach out
to them. This means embracing methods
of communication that match consumer
preferences and help provide a frictionless
"The overarching trend that we're seeing
is that consumers don't like responding to
phone calls, right-party contacts are going
down and letters are practically never read,"
said Ohad Samet, president of TrueAccord.
"It's obvious that consumers are looking for
other communication channels."
It makes sense. After all, your clients
market to consumers online, originate them
online and service them online. Then those
same consumers are referred to collections,
where they receive printed letters and phone
calls (often on landlines, if available). This
disconnect is more than just an annoying
shift-it might be seriously affecting your
That's part of the reason why TrueAccord
relies on emails and texts more than
"I see self-service as a panacea for first-party and
third-party debt buyers and collection agencies
because you're taking the cost of the collector out
of the equation and minimizing compliance risk."
printed letters and phone calls to reach
consumers. In fact, Samet noted that phone
conversations are "only for cases where we
cannot reach the consumer with a selfservice or data-driven solution. Our goal was
to flip the numbers compared to a traditional
call center. In our case, more than 90 percent
of accounts are being resolved online using a
system that is machine-learning-based rather
than by talking to a person."
TrueAccord does maintain a small call
center: one agent for every 50,000 to 70,000
accounts, Samet estimated. But mostly
its machine-learning system does the
work, generating communication profiles
based on consumers' behavior. (Did they
open the email? Did they respond to the
text?) The system uses this information
to customize the method and content of
each communication to suit consumer
Samet noted that there are big risk
management benefits that come from
using this personalized-and carefully
scripted-approach to digital consumer
"The system doesn't get tired, it doesn't
argue with a significant other or stress
about making its numbers at the end of
the month," Samet said. "For the majority
of cases, as long as there is enough data
available about the consumer, machines are
better at being consistent and compliant."
For traditional debt collection agencies,
which are solidly rooted in the call center
environment, this all probably sounds
great but perhaps somewhat unachievable.
However, in addition to investing in
artificially intelligent collection software,
which is out there, there is a pretty lowtech way for you to cater to consumers'
communication preferences that you can
start doing right now: ask them what they
"It's one thing to ask consumers the best
way you can reach them, and it's another
thing to say, 'OK, you want me to call
you-now, when can I call you? What's
the best time of day?" said Adam Barrett,
director of product management for FICO.
"That's asking for their permission and their
preference. If you respect those preferences,
you'll get much better results because
you'll be more responsive. It goes beyond
that too-making it clear that you want
to empower people so they feel they have
different options to resolve their situation."
Of course, digital communications present
a new and intimidating frontier for many
debt collection agencies. "There's really
not a lot of case law on email and texting,"
DeSaulniers acknowledged. "These are the
ways consumers want to interact with us
but there is very limited guidance from
regulators on those options."
However, there are debt collection
agencies that have created comprehensive
email and even texting programs, working
with their legal counsel to make sure they are
as compliant as possible. A big part of this is
consent: getting it and recording it.
Another piece is making that consent easy
to revoke if consumers ever change their
mind. You might want to consider including
this option in all texts and emails; creating a
page on your website that allows consumers
to tweak their communication preferences is
PROVIDE EASY PAYMENT OPTIONS
You can order your coffee before you step
foot in the coffee shop. You can pay for your