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 ACAINTERNATIONAL.ORG
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