Collector - December 2017 - 28

on post-disaster communication strategies,
owned a collection agency when Hurricane
Andrew struck Florida in 1992. "I had 15
clients telling me to do things in 15 different
ways," he recalled. "A disaster that big was
new to them, and some of their directives
were not so great."
Talk to your clients about their messaging,
too. Sending them ZIP codes of areas
hardest hit can give them an opportunity to
express their concern for consumers after a
disaster and boost their brand. Several banks
and credit card companies did this after
hurricanes Harvey and Irma.
For instance, Wells Fargo told customers
in FEMA-declared areas that it would
provide "payment relief " for 90 days on
several of its credit lines, including credit
cards, student loans and mortgages, and
wouldn't report missed payments to
consumer reporting bureaus.
If your clients have hardship or relief
programs, Schultz suggested collection
agencies could let their customers
know about them and recommend
they document any damages and costs
incurred as a result of the disaster for
their application to the program. In
these situations, it's essential to have an
employee on the line who is well versed
with the client's specific hardship program.
Even posting a notice on your website
that your thoughts are with those affected

28

by the recent natural disaster and
describing the support your company is
offering victims and/or relief efforts can go
a long way toward building goodwill with
clients and consumers.
Additionally, think about how you will
communicate with your clients if the power
and phone lines go out in your area. When
Hurricane Irma hit Florida on Sunday, Sept.
10, David Kelley, president and CEO of
The Preferred Group of Tampa, closed his
company that Monday.
Even though it wasn't in an area that
received significant damage or flooding,
the company's offices were in a designated
evacuation area and they had to wait until
the all-clear was given by city officials.
Kelley reopened the office doors on Tuesday
morning, and it took him all day to connect
with his Florida-based clients, many of
which were without power and had enacted
their own emergency preparedness plans.
"That day, we communicated our status
to our clients, asking them to share with us
any pertinent things we needed to know,"
he said. "We also gave them our game plan
on how we would approach and when
we would begin calling their patients,
and asked if they wanted us to vary that
approach at all. None of them did. I can't
tell you all the positive responses we got
from getting in touch with our clients right
away and asking how we can support them."

FROM A LEGAL PERSPECTIVE
Of course, there are a few legalities you will
need to take into account when formulating
your post-disaster communication plan.
Consumers who live in the areas most
heavily hit may not be able to send and
receive mail. Your collection letters, as
well as your service of summons and
complaints, could be nearly impossible
for consumers to receive; in some cases,
local post offices or courthouses might be
demolished.
Your collection efforts in these areas
during this time would likely not only
be fruitless, but could put you at risk if
you proceed with actions at a time when
consumers can't receive your letters.
While neither the Fair Debt Collection
Practices Act nor the Fair Credit Reporting
Act require proof of receipt when sending
collection notices to consumers, after a
disaster it may be impossible to comply
with their notice requirements due to
interruptions in telephone and mail service.
Many debt collectors opt to suspend
communication attempts until mail is
deliverable or telephone service is restored to
the disaster-stricken area.
It might be helpful to reference the U.S.
Postal Service's list of areas where mail is
suspended due to a natural disaster, which
can be found on its website. USPS updates
the service disruption status of affected ZIP

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