Collector – October 2019 - 23

Some collectors have expressed
concerns about third-party disclosure
when discussing debts with a consumer
who uses an interpreter or relay service.
The Federal Trade Commission has
historically interpreted the thirdparty disclosure prohibition to exclude
incidental contact with telephone
operators and telegraph clerks.
Interpreters and relay service employees
facilitating communication on behalf
of a consumer with a disability would
generally fall under that exclusion.
"A relay service is really an
extension, agent or authorized person
under the FDCPA," Bedard said. "It's
unlikely to be a viable legal claim for a
person with a disability to request an
auxiliary aid through a relay service
to communicate with a collector and
then subsequently file a third-party
disclosure lawsuit against a collector
for using that very service."

WEBSITES
Websites are also a key point of contact
between consumers and collectors.
Ensuring your website is accessible
by those who are visually impaired is
essential for ADA compliance.
"You need to make your primary
website goal that someone who is visually
impaired can find the information easily
and that you're not hiding it or masking
it," said Susan Hickman, collection and
compliance manager for ISPC. "Using
white text on a black background or black
text on a white background are the best
options. Be aware of the readability of
your font size, and don't use anything in
the design that is too busy."
The World Wide Web Consortium
(W3C), an international group that
develops website standards, has published
its Web Content Accessibility Guidelines
(www.w3.org/TR/WCAG20) to help
companies and individuals make their
sites accessible to people with blindness,
impaired vision and other disabilities.
Some of the practices W3C
recommends include:

COLLECTOR 10.19

* Provide text alternatives for any
non-text content. Include meta tags
so images, video and other media
content include text descriptions
that can be read by screen reader
devices and software.
* Make it easy for users to see and hear
content. Don't use color as the only
way to convey information. Ensure a
significant contrast between text and
background colors. Ensure content can
be resized up to 200% without it being
cut off or losing website functionality.
* Provide users enough time to
read and use content. Content or
transactions that become inactive
within a specified timeframe may
present challenges for individuals
with dexterity issues.
* Avoid content that may cause
seizures. Content that flashes
multiple times can trigger seizures
for some individuals and is best
avoided.
Free online evaluation tools (http://
wave.webaim.org) are available to analyze
web pages and show which elements
fall outside of W3C guidelines. Web
designers can use these resources to
ensure accessible design.
Complying with any law or
regulation can present challenges.
Being aware of the requirements,
following official guidance and best
practices, and keeping the ultimate
goal in mind-providing accessibility
to everyone-can help businesses not
only comply with the ADA, but also
improve their overall service.
"You have special situations,"
Hickman said. "As a company, you
can't always fit everyone in a one-sizefits-all box. Collections are an offshoot
of customer service, and sometimes
we need to respond to customers'
individual needs to ensure they have
the same service as everyone else."
Tim Dressen is a communications consultant
and former editor of Collector magazine.

1

Create clear policies
and procedures for
communicating with
consumers with a disability.

2

Make sure content on
your website can be
resized up to 200% without
it being cut off or losing
functionality.

3

Accept requests from
individuals with a
disability or by someone
acting on their behalf.
Specify who should receive
such requests in advance,
when possible, but note
that all requests need to
be handled promptly.
23


http://wave.webaim.org http://wave.webaim.org http://www.w3.org/TR/WCAG20

Collector – October 2019

Table of Contents for the Digital Edition of Collector – October 2019

President’s Page
Industry News
Best Practices
FYI
Collection Tips
Accessibility From Every Angle
Information Transformation
Calendar
Honor Roll
Education Spotlight
Behind the Name
A.I. is Transforming Compliance. Are You Ready?
What to Watch in 2020
ACA’s Industry Advancement Program Provides Amicus Support in Key FDCPA Statute of Limitations Issue
ACA SearchPoint
Ad Index
Membership
Last Word
Collector – October 2019 - Cover1
Collector – October 2019 - Cover2
Collector – October 2019 - 1
Collector – October 2019 - 2
Collector – October 2019 - 3
Collector – October 2019 - 4
Collector – October 2019 - President’s Page
Collector – October 2019 - Industry News
Collector – October 2019 - 7
Collector – October 2019 - 8
Collector – October 2019 - 9
Collector – October 2019 - Best Practices
Collector – October 2019 - 11
Collector – October 2019 - FYI
Collector – October 2019 - 13
Collector – October 2019 - Collection Tips
Collector – October 2019 - 15
Collector – October 2019 - 16
Collector – October 2019 - 17
Collector – October 2019 - 18
Collector – October 2019 - 19
Collector – October 2019 - Accessibility From Every Angle
Collector – October 2019 - 21
Collector – October 2019 - 22
Collector – October 2019 - 23
Collector – October 2019 - Information Transformation
Collector – October 2019 - 25
Collector – October 2019 - 26
Collector – October 2019 - 27
Collector – October 2019 - 28
Collector – October 2019 - 29
Collector – October 2019 - Calendar
Collector – October 2019 - Honor Roll
Collector – October 2019 - Education Spotlight
Collector – October 2019 - 33
Collector – October 2019 - Behind the Name
Collector – October 2019 - 35
Collector – October 2019 - A.I. is Transforming Compliance. Are You Ready?
Collector – October 2019 - 37
Collector – October 2019 - What to Watch in 2020
Collector – October 2019 - 39
Collector – October 2019 - 40
Collector – October 2019 - 41
Collector – October 2019 - ACA’s Industry Advancement Program Provides Amicus Support in Key FDCPA Statute of Limitations Issue
Collector – October 2019 - 43
Collector – October 2019 - ACA SearchPoint
Collector – October 2019 - Ad Index
Collector – October 2019 - Membership
Collector – October 2019 - 47
Collector – October 2019 - Last Word
Collector – October 2019 - Cover3
Collector – October 2019 - Cover4
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