Tag: CFPB

One True Holding Company writes to the CFPB

By on March 24th, 2020 in Company News

The Consumer Financial Protection Bureau’s Notice of Proposed Rulemaking (NPRM) is set to help shape massive changes to the debt collection industry. In an effort to continue our mission to protect consumers from predatory and aggressive collections experiences, the co-founder of TrueAccord, Ohad Samet, recently drafted a letter to the CFPB’s Director Kathleen Kraninger.

In the midst of major economic uncertainty, we understand that we must be compassionate when many consumers are struggling financially. Offering consumers in debt flexibility by supporting and expanding the industry’s digital infrastructure enables us to extend self-service options to those that need it most and limit their exposure to collections efforts that are intrusive and harassing. 

Some states are considering freezing collections efforts, but we continue to believe in consumers’ ability to manage their finances for themselves. Access to online portals and self-service payment plan adjustments can help them manage their overdue accounts at their own pace, even in times of financial instability. A complete suspension of their ability to pay, if and when they can afford it, can make matters worse.

Passing the NPRM into law can help to restructure collections to protect consumers today. 

You can read our letter to Director Kraninger below:

Our letter to the Consumer Financial Protection Bureau

Dear Director Kraninger,

I am the CEO of One True Holding Company, a technology company providing business- and consumer-facing solutions in the debt collection space. Our subsidiary TrueAccord Corp. offers machine learning-based, digital- and mobile-first servicing for debt in collections and recoveries. Our subsidiary True Life Solutions offers consumers a SaaS platform that consumers can use to contact collectors and creditors digitally.

We service millions of consumers on a monthly basis, sending more than 18 million emails a month. As a technology startup at the forefront of debt collection efforts, we have both quantitative and qualitative views of the state of the economy and debt collection within it.

Times like these require swift action, and technology allows us to empower consumers while reacting to changing circumstances without having to re-train a large workforce. Since the crisis began, we have been able to seamlessly launch features allowing consumers to modify their payment plans on their own and set up longer and more flexible payment arrangements. We are launching tools for clients to offer automated digital relief programs. Consumers still interact often with the emails we send as they try to stay abreast of their finances and remain informed. 1

Our pandemic response page, offering tools and perspectives about finances in this time, sees more than 1,200 daily visits. Technology offers better service, a sense of empowerment and agency, and keeps our users informed through complicated circumstances. As a consumer-focused company, we carefully track our customer satisfaction (CSAT) scores, and those have remained high (at 68.45% for the month of March). Consumers appreciate our approach, as these reviews also show:

Consumer review from 3/19/20 

You were patient. All emails were kind even from the beginning of my debt. You motivated me to repay my debts and monitor my credit. You appreciated me and I felt the extraordinary customer service from the day I first took the loan. I am grateful and even during this pandemic [emphasis added] I felt my loyalty to complete my payment of this loan over any other bill. Thank you again!

Consumer review from 3/18/20

Settled in a manner that facilitated affordable payments on a schedule that fit my life. I wish all collection agencies were this caring and flexable [sic]. Hopefully, I’ll never have another collections account, but if I do, I pray it’s with this agency.

As a single father making minimum wage, finding money to pay bills that aren’t crucial to keeping my kids healthy and happy is a real struggle, and my credit score had taken the hit in the past. I am really, truly grateful this is one acct that gets crossed off my list. Thanks!

I write today to ask the CFPB to accelerate its NPRM and swiftly push the industry to rely predominantly on digital communications for the purpose of debt collection. We need to continue to communicate with consumers through their channel of choice, in a non-intrusive manner, allowing them to easily manage their finances while controlling who they want to interact with. We need to continue to allow them to access their accounts and make adjustments to fit their personal circumstances.

Through this last week consumers have continued to set up customized payment plans on a daily basis, at a rate comparable to pre-tax season behavior. These are consumers acting on their own, responding to our low-frequency digital contact efforts. Finances aren’t one-size-fits-all, and a digitally native collection service supports this variety even in these trying times.

Thank you for your consideration and leadership in these trying times. We are eager to share as much data and qualitative observations as possible to support your policy-making and continue this conversation with a focus on consumer protection, choice, and experience

Citations

1. More than 20% open rate per each individual email broadcast as of 3/21, comparable with and exceeding eCommerce benchmarks

TrueAccord Submits Debt Collection NPRM Comments

By on September 19th, 2019 in Company News, Compliance
man_signing_document

In an effort to further improve the debt collection experience for consumers, TrueAccord filed comments in response to the Consumer Financial Protection Bureau’s (CFPB) Notice of Proposed Debt Collection Rulemaking. Our experience using mostly email to communicate with consumers about their debts gives us the unique ability to provide detailed feedback to the CFPB on the parts of the Proposed Rule that impacts the use of email, data science, and machine learning in debt collection. 

We know that consumers in debt collection benefit from both email communications and machine learning technologies. Email communications allow consumers to access content at their convenience (including emails that contain legally required disclosures); new machine learning technologies provide additional information and payment options based on the consumer’s interactions to further personalize their collections experience.

What are we suggesting?

Make the transition into collections communication simpler

When emailing a consumer, either an initial communication—one containing the validation notice in the body—or any communication relating to the debt, a debt collector should be able to contact that consumer at the email address that the consumer provided to the creditor. 

The proposed rules do not currently provide this option without causing an undue burden on consumers. TrueAccord highlighted that unnecessary restrictions in the proposal greatly limit the ability to communicate with consumers via email. Consumers who have already provided their preference for electronic communications to their creditor(s) would be forced to take extra steps because they have fallen into collection. 

Define and properly evaluate email as a unique medium

Our customers regularly tell us that email is very different from phone calls and even paper mail. As such, email communications warrant different treatment under the FDCPA and should not be subject to the standard time, place, and manner restrictions that were designed for and apply to primarily oral communications.

TrueAccord asked the Bureau to take this opportunity to further modernize the FDCPA by distinguishing that certain provisions do not apply to email. 

Recognize other, optional forms of electronic communications as legitimate

We raise concerns over the proposed definition of “attempted communication” and “limited content message.” The current proposed definitions have the unintended consequence of limiting digital advertising and other electronic messages that consumers can opt-in to receive. 

What is our goal?

TrueAccord’s suggested changes will increase the proposed rule’s ability to make collections more efficient, provide actual notice to consumers, give consumers immediate access to information, and enable consumers to control how they want to communicate.

The debt collection proposed rulemaking is an opportunity to empower the vast majority of consumers who prefer to communicate electronically. The Bureau must take advantage of this opportunity.

You can read TrueAccord’s full comments here.

The FCC is Saying: Give Consumers Communication Choices

By on July 24th, 2015 in Compliance
TrueAccord Blog

Choice is inherent in the way we, as 21st century consumers, interact with our world. The choice to eat whatever we want. The choice to take whatever form of transportation we like. The choice to marry whomever we wish. The concept of choice in debt collection isn’t revolutionary; debt collection has always been linked to the consumer experience. Yet, recent crack downs on bad actors in the debt collection space by the CFPB, as well as the July 10th ruling from the FCC feels like an affirmation of how TrueAccord approaches debt collection.
Continue reading “The FCC is Saying: Give Consumers Communication Choices” →