Collector - October 2020 - 23

departments that affect those KPIs can
improve efficiency and increase value.
For example, when it comes to complaint
management, frontline collectors do not
want to spend their time on calls where
the consumer has a complaint with the
product, service, underlying debt or
prior collection agent, or is disputing
the debt. Yet, by using active listening
and problem-solving strategies, properly
trained representatives can diffuse these
calls, letters or prelitigation demands. This
saves the organization real dollars by not
having to defend-or settle-litigation. In
some instances, well-handled complaint
management can generate payments by
helping the consumer understand the debt
history, resolving an underlying concern,
addressing the disputed portion of the
debt or simply explaining the situation in
different terms.
Complaints function as both a KPI
and KRI. Agencies should be tracking
the number and types of complaints and
escalations they receive, and sorting them
by individual phone agents, manager/team,
issue, client and other criteria. Compliance
and quality assurance departments can
look for patterns or trends in this data to
develop ongoing, individualized training
and other resources.
We've often heard compliance must be
separate from operations, and that is true
from a reporting and organizational structure
perspective. However, compliance must
also be integrated into the very fabric of the
operation. Compliance and quality assurance
teams should review phone calls, which
directly impact (positively or negatively)
a phone agent's commission. This should
also roll up to the manager's commission
or bonus when looking at the manager's
team compliance and adherence to quality
assurance standards. While compliance and
quality assurance are independent from
operations, they are intricately woven into all
aspects of operations.
The compliance team works to be proactive
in helping to operationalize the rules and
regulations, and to watch for what's coming
next. True compliance that is part of an

COLLECTOR 10.20

organization's DNA begins (and ends) with
the front-line phone agents.
Compliance is everyone's job. The more
organizations embrace this and insert
compliance line-of-sight into more aspects of
the organization, the stronger the organization's foundation, CMS and bona fide
error defense will be. The organization will
be more efficient and profitable because it
solved issues before they started by integrating compliance features into the process,
protocols and systems in the planning phase
rather than having to retool the systems
prior to launch because compliance aspects
weren't considered earlier.

LOOKING AHEAD
An agency's CMS and quality assurance
program are always evolving. The CFPB is
set to release its final debt collection rules
this October, which will mandate the next
step in the evolution. The implementation
of those rules will depend on the upcoming
election and compliance deadlines may
vary, from 2021 to as late as 2023.
What is certain is that today, agencies
face a choice of whether they want their
CMS to evolve proactively through industry
innovation so they can begin to define and
drive their quality assurance, or reactively
through increased regulatory requirements,
letting regulatory bodies continue to
define their CMS. By taking action now,
organizations have the opportunity to
accelerate and have some control over this
evolution, rather than being reactive and
"dealing with" whatever is imposed on the
industry. We choose to lead this effort and be
the change we want to see in the industry.
Porter Heath Morgan, Esq. is a partner with
the law firm Malone Frost Martin and serves
as general counsel at Morgan Financial
Group. He is based in Colorado.
Wendy Badger, Esq., CCEP serves as special
compliance of counsel with Ovaile Law Group.
She is also a Corporate and Compliance
Ethics Professional certified by the Society
for Corporate Compliance and Ethics. She is
based in Minnesota.

1

Your compliance
department should have
a clear line of sight into each
area of the company.

2

Involving compliance in
the development of new
processes and programs
ensures they are built on an
ethical foundation.

3

Use KPIs to help
you prioritize your
compliance department's
expansion.
23



Collector - October 2020

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