Collector - November 2017 - 25

Regulators talk with one another, and
information from state audits is sometimes
shared with other city, state and federal
regulatory agencies. That means an issue
identified in your Massachusetts audit likely
won't go unnoticed in Illinois, for example,
even if you don't bring it up yourself.
"If despite your efforts a regulator
imposes some sort of civil investigation
fine or penalty, it's important to jump
on those as quickly as possible," Bender
said. "There are some piggy-back states
that require you to notify them if another
regulator has cited or fined you. If they
find out before you tell them, it's a red flag
for them."
Not only is it a red flag, but failing to
report a violation could cause you to lose
your license.
Self-reporting might seem like it could
potentially bring more fire down on you
but Storvick said, at least in Washington,
it's not as big of a deal as you might think.
"We receive notices like that every
week," Storvick said. "To us, it's not
strange or unusual to get a letter from a
company telling us they had a sanction,
and most of it leads to nothing in
Washington other than us going, 'Oh,
there's another one.' And if you look at
our laws, you'll see there's no caveat in
there that says if an agency reports a
violation they can't be licensed. But it
does say if they don't report it, they can't
get licensed."
Similarly, regulators want and even
expect you to keep an eye out for
wrongdoing in your state. If you find out
someone is doing something potentially
illegal, regulators want agencies to report
it even if you don't know who exactly is
responsible for the questionable behavior.
"If you let us know, even though we
may not have teeth to go after them, we
collect that information and share it with
other states and the FTC," Storvick said.
"If we get enough reports from enough
places, maybe someone can nail it down.
Collection agencies are doing a service to
our communities, and we need to make
sure you have a fair playing field."

COLLECTOR 11.17

IF YOU NEED MORE TIME,
ASK FOR IT
Identify the individuals within your
organization who should be involved in
an examination or audit and spell out
their roles so they will be prepared when
document requests roll in.
Talk to your CFO or accounting manager
to determine how difficult it will be to
get the information. Is it in storage or are
the documents readily available? These
conversations will help you block out time to
get the data and paperwork pulled.
If it looks like you'll need extra time to gather
the requested audit documentation, don't panic.
"I've found that sometimes the
documentation request deadlines and even the
examination dates are negotiable," Ciskey said.
If you need to ask for an extension, you'll
want to negotiate those dates as early as
possible. Regulators appreciate agencies that
are proactive and open about these issues,
and if you reach out to them immediately,
they will likely grant you the time you need-
within reason.

COMPLIANCE CREATES A
LEVEL PLAYING FIELD
Understanding and adhering to state
licensing rules, while time-consuming
in the short term, can yield tremendous
benefits in the long term.
"The number of actual licensed companies
in Washington that we get complaints against is
minimal," Storvick said. "Most of our consumer
complaints against collection agencies are
actually against unlicensed agencies, and I don't
consider them to be collection agencies-they
are just people out on the street. In all honesty,
I think they give your industry a bad name.
When you see something reported in the news,
most often the agencies they are describing
were unlicensed and might not even know
what the laws and rules are. But agencies that
are involved in their industry association rarely
find themselves in trouble because they know
the rules and laws and work to keep up with
them."
Anne Rosso May is editor of Collector
magazine.

KEYNOTES

1

If you miss a licensing
renewal or audit
paperwork deadline, the best
course of action is to call
the regulator immediately
and explain. Owning up to
the mistake buys you some
credibility.

2

Call your state regulator
directly if you have a
question about the scope of
an audit or need to clarify
how a requirement should
be interpreted.

3

If the state has migrated
to the Nationwide
Multistate Licensing System
and Registry, regulators will
likely want to ensure you've
kept up with what's on the
NMLS site and that your
collection letters conform.
25



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

Upfront
Industry News
Best Practices
FYI
Collection Tips
Making the Right Choice
Getting Your Ducks in a Row
Highlight Reel
Putting it all Together
Calendar
Honor Roll
On Call
Hire Purpose
CFPB Pursues Two Student Loan Servicers
Compliance
ACA SearchPoint
Last Word
Collector - November 2017 - Cover1
Collector - November 2017 - Cover2
Collector - November 2017 - 1
Collector - November 2017 - Upfront
Collector - November 2017 - 3
Collector - November 2017 - Industry News
Collector - November 2017 - 5
Collector - November 2017 - 6
Collector - November 2017 - 7
Collector - November 2017 - Best Practices
Collector - November 2017 - 9
Collector - November 2017 - FYI
Collector - November 2017 - 11
Collector - November 2017 - Collection Tips
Collector - November 2017 - 13
Collector - November 2017 - Making the Right Choice
Collector - November 2017 - 15
Collector - November 2017 - 16
Collector - November 2017 - 17
Collector - November 2017 - Getting Your Ducks in a Row
Collector - November 2017 - 19
Collector - November 2017 - 20
Collector - November 2017 - 21
Collector - November 2017 - 22
Collector - November 2017 - 23
Collector - November 2017 - 24
Collector - November 2017 - 25
Collector - November 2017 - Highlight Reel
Collector - November 2017 - 27
Collector - November 2017 - 28
Collector - November 2017 - 29
Collector - November 2017 - 30
Collector - November 2017 - 31
Collector - November 2017 - Putting it all Together
Collector - November 2017 - 33
Collector - November 2017 - 34
Collector - November 2017 - 35
Collector - November 2017 - Calendar
Collector - November 2017 - Honor Roll
Collector - November 2017 - On Call
Collector - November 2017 - 39
Collector - November 2017 - Hire Purpose
Collector - November 2017 - 41
Collector - November 2017 - CFPB Pursues Two Student Loan Servicers
Collector - November 2017 - 43
Collector - November 2017 - Compliance
Collector - November 2017 - 45
Collector - November 2017 - ACA SearchPoint
Collector - November 2017 - 47
Collector - November 2017 - Last Word
Collector - November 2017 - Cover3
Collector - November 2017 - Cover4
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