Life at TrueAccord: September Edition

By on October 2nd, 2017 in Company News, Culture

September has been a busy month at TrueAccord. We wanted to share some of the highlights as we take a break from it all and enjoy some themed food and drinks at our weekly happy hour. Since September in SF is one of the nicest months, we took our happy hour to a rooftop BBQ in SOMA, we just couldn’t pass up the opportunity to hold on to summer for a bit longer and enjoy a great evening with our coworkers.

We are also growing quickly, all our teams are expanding, and we added some key hires in September to help us delight our customers and build a platform for financial health. We added David Han (Implementation Manager), Tim Collins (Chief Compliance Officer), Gopi Karunamoorthy (Accounting Assistant), Adam Gomez (Senior People Operations Associate), Matt Botts (Customer Success Manager), Lilia Paz (Customer Engagement Specialist) Nick Bright (Customer Engagement Specialist), Tyler Watt (Customer Engagement Specialist). Come work with us!

Yelp Partners with TrueAccord to Deliver Digital Collections and Streamline Data Loop for Customer Engagement

By on September 28th, 2017 in Company News, Debt Collection, Industry Insights, User Experience

Highlights:

“TrueAccord saved our collections team tons of time, the integration with their system was fast and easy, without needing to do tedious, manual tasks.”

“Our company goal is to grow a large, loyal and happy customer base. TrueAccord’s digital collections process supports our goals by extending a great user experience to the collections process.”

“Digital, personalized collections are driving high engagement rate.”

“With TrueAccord we have timely data into customer standing.”

Challenge:

Yelp was founded in 2004 and is now one of the largest platforms to connect people with great local businesses. Traditional agencies required a lot of man-hours and manual processes.  Yelp faced several challenges with the traditional agencies; first, they required a manual process to transfer debt accounts, which was both time-consuming and tedious, requiring lots of forms and faxes being sent, lacking automation and data tracking functionality that Yelp required for business success.  Second, the agencies were employing traditional collections tactics that did not adhere to Yelp’s values.

 Why TrueAccord:

Yelp was looking for a collections agency that would increase recovery rates and help the collections team save time by automating the account transfer process as well as deliver great consumer experiences to support their brand and customer satisfaction. They needed a data-driven collections process that would streamline the visibility into consumer account status, so they could better serve their customers and run their business.

“TrueAccord’s digital collections process was a natural fit for Yelp,” says Parker Asche, Senior Collections Analyst. Yelp’s customers are used to digital interaction, and TrueAccord’s consumer-centric, digital collections process was an extension of our business practices.

Benefits:

“TrueAccord saved our collections team tons of time, the integration with their system is fast and easy, without needing to do tedious, manual tasks.” TrueAccord makes it easy for Yelp to continuously feed new account data into the system, without burdening their collections team with paperwork, saving the team time to focus on business objectives.  The quick transfer and collections process helps their business to continuously keep their customers engaged.

Consumer preferences are changing, and they demand a modern approach to communications. TrueAccord enabled Yelp to reach their customers via a communication method they prefer and engage with, and empower them with the ability to self-service themselves. Yelp is using TrueAccord to deliver engaging digital user experiences for their customers.

About Yelp:

Yelp Inc. (NYSE: YELP) connects people with great local businesses. Yelp was founded in San Francisco in July 2004. Since then, Yelp communities have taken root in major metros across 32 countries. By the end of Q2 2017, Yelpers had written approximately 135 million rich, local reviews, making Yelp the leading local guide for real word-of-mouth on everything from boutiques and mechanics to restaurants and dentists. Approximately 28 million unique devices* accessed Yelp via the Yelp app, approximately 74 million unique visitors visited Yelp via mobile web** and approximately 83 million unique visitors visited Yelp via desktop*** on a monthly average basis during the Q2 2017. For more information, please visit http://www.yelp.com or send an email to press@yelp.com.

* Calculated as the number of unique devices accessing the app on a monthly average basis over a given three-month period, according to internal Yelp logs.
** Calculated as the number of “users,” as measured by Google Analytics, accessing Yelp via mobile website on a monthly average basis over a given three-month period.
*** Calculated as the number of “users,” as measured by Google Analytics, accessing Yelp via desktop computer on an average monthly basis over a given three-month period.

Press Release: Tim Collins Joins TrueAccord as Chief Compliance Officer

By on September 25th, 2017 in Company News, Compliance

TrueAccord, the debt collections technology company, has hired Tim Collins as Chief Compliance Officer. TrueAccord’s platform is powered by machine learning that uses a consumer centric, data-driven approach to help businesses recover more debt online than traditional methods. Collins joins TrueAccord from Convergent Outsourcing, where he was General Counsel and Chief Ethics & Compliance Officer since 2013.  

Collins has more than 25 years of experience in collections, having held leadership roles in legal and compliance at various financial organizations, including Hyundai Capital America where he established a comprehensive compliance system across all areas of the business. In his new role at TrueAccord, Collins will oversee the company’s legal and compliance practices to meet the requirements of the highly regulated debt collections industry.

“Having an industry veteran such as Tim join our team is a testament to the strength of our business and the major clients we represent, as well as our vision for how to transform collections for good,” said Ohad Samet, Chief Executive Officer. “The top 10 banks and lenders who use TrueAccord demand the highest level of compliance. Tim’s deep and relevant expertise will ensure we consistently meet and exceed their expectations.”

“After following TrueAccord for the past few years, I have been intrigued by their unique approach to debt collection, an industry that in my experience is ripe for disruption,” said Tim Collins, Chief Compliance Officer. “With an inspiring vision, a strong product, and an exceptional management team, TrueAccord is well-positioned for accelerated growth and investment. I look forward to contributing to the company’s continued success and to helping shape the future of the collections industry.”

Collins received his JD from the University of Detroit Mercy School of Law, and completed his Bachelor’s Degree in Business Administration at the University of Iowa’s Tippee College of Business. Collins is an adjunct professor at the University of San Diego Law School where he teaches seminars on in-house corporate practice; and he also serves on the Federal Affairs Committee for ACA International, the Association of Credit and Collections Professionals.

About True Accord

Founded in 2013, TrueAccord’s data-driven debt collection platform is disrupting the collections industry by helping businesses collect more debt online than traditional methods. The platform is powered by machine learning, with a decision engine that analyzes consumer behavior and delivers personalized consumer experiences by communicating at the right time in the right channel with payment options that meet their needs. TrueAccord is providing exceptional recovery rates for top 10 financial institutions, debt buyers, lenders and technology companies, and is empowering many of the estimated 77 million consumers who are in debt every year to get on a path to better financial health. To learn more, go to: www.trueaccord.com.

Industry Expert Says: Phone Calls Are Dying

By on September 12th, 2017 in Compliance, Debt Collection, Industry Insights, Machine Learning

Yesterday, in an article on InsideARM.com, Tim Bauer, the President of InsideARM, described a somber state of affairs:

The TCPA and the 2015 FCC Rules interpreting the act have effectively eliminated the use of technology to efficiently call cell phones. Land line usage is dropping like an anchor. The CFPB is on the brink of announcing proposed debt collection rules that are likely to reduce the number of call attempts that can be made. Now, add this latest call blocking technology and the industry is challenged again.

This is a strong statement from a prominent thought leader in the debt collection industry. Mr. Bauer pointed out many efforts by different regulatory agencies and how they impact call centers: “anecdotal reports of right party connects down by 15-30%”, as the FCC includes debt collection calls as an “unwanted call” category in it’s “robocall” blocking initiatives.

At TrueAccord, we agree. The industry has been seeing tremendous pressure on its ability to call consumers efficiently, not only because of regulatory pressure – this pressure is driven by consumer preference, and the fact that consumers often opt to not pick up the phone, not to mention opening a letter. As strong advocates for technology in debt collection, with our CEO now part of the CFPB’s Consumer Advisory Board, we will continue to support forward thinkers such as Mr. Bauer and others who call for the use of new technologies in debt collection. It is the consumer friendly, smart, and efficient approach for the 21st century, and we strongly encourage our peers in this industry to begin adopting and utilizing these channels in preparation for the CFPB’s expected Notice of Proposed Rulemaking, expected later this year.

Meet Our Engagement Team Members

By on August 29th, 2017 in Company News, Culture

TrueAccord’s mission is to reinvent the debt collections space by delivering great consumer experiences that empower consumers to regain control of their financial health and help them to better manage their financial future.  We are reinventing debt collection with data driven, personalized, digital first collections.  

While technology is helping reinvent debt collection and forge a better way to communicate with consumers, not all personal interactions can, nor should be replaced.  This is where our customer engagement team is making a huge impact in the process and engaging with customers to help them through a difficult time.  

Meet a few of our engagement team members and hear their stories.  

Meet Dean-Austin Mayor

   

Tell me a bit about yourself?

“I graduated from Santa Clara University in 2016, I studied psychology and music. I wanted to apply my degree to help people. The mission really attracted me to the company, it was about helping people and it was the real thing here.”

Why TrueAccord?

“After interviewing with the team, I really believed the company was focused on the idea of helping people through a tough situation.  I would have the opportunity to empathize with people and give them a better experience.”

What keeps you coming back?

“The culture.  Everyone works together, people are smart, the energy is very positive here.  I’m exposed to working with other teams, it’s a very collaborative environment and we’re all working towards the same goal.   It’s a great place to be even if I have a tough day.”

Advice for someone considering a role?

“It takes a level of compassion to have patience and understand where people are coming from, so you can understand them and work with them.  But don’t take things personally, not everyone wants to work with us, so you will have to handle difficult situations. But there are so many customers that are so surprised by how nice we are and how different.”  

What are the benefits like?

“They really care about the employees and provide great benefits.   We also have weekly happy hours, and a culture committee that plans events.”

Meet Kelly Young

Can you tell me a bit about yourself?

“I am a bay area native, and when I moved back after college I was looking for my first job, and wanted to get experience in a growth stage startup. I was looking for a place to learn and the opportunity to grow. I was intrigued by what TrueAccord does.”

Why TrueAccord?

“The interview process was very fast and engaging.  I talked to a lot of people during the interview process and it felt like people were genuine, friendly and took the time to get to know me. It seemed like a great place to work.”

What is the culture like?

“There is a culture of learning here and changing things for the better.  People are constantly coming up with new ideas and better ways of doing things.  It’s great to be part of a company where I can see my ideas come to life.”

“Everyone is really smart here, they work hard, but there is a great work/life balance.  We are focused and prioritize what needs to be done, and when faced with a difficult situation or challenge we come together as a team.”

“It’s a great place to gain experience and grow with the company, this role is a chance to get in on the ground floor.  I’ve seen a lot of agents move to other roles, growth is definitely a huge thing here.”

What is the role like?  

“It’s challenging but rewarding, we are helping people in difficult situations. A lot of consumers have been in debt multiple times and have dealt with traditional agencies, so they don’t expect us to be there to help, but that is exactly what we do.”

What are the benefits like?  

“It’s a great office in downtown SOMA, open space, standing desks, great snacks, lunches, dog-friendly.  We also have weekly themed happy hours on Wednesdays, a nice way to break up the week and have fun.”

Meet Serena Cabrera

Tell me a bit about yourself?

“Originally I’m from LA. I graduated from Berkeley and really liked the Bay Area and wanted to stay here.  A friend referred me in, and I didn’t know much about the company, but then I researched, umm debt collection, I was skeptical.  But once I talked to everyone and learned about the way TrueAccord is really trying to change the industry, I took the leap.”

Why TrueAccord?

“It was the people that really made me want to come here, everyone was friendly and open, and there were great benefits.”  

What’s the Culture Like?”

“It’s a very open culture of bringing up questions and ideas and everyone collaborates. I was learning a lot, and everyone was very supportive.”

What keeps you coming back?

“It’s a great place to learn, this has given me the opportunity to be in tech. I’m still trying to figure out what I want to do, and there are great people here to learn from and have exposure to other departments and mobility. I’m interested in UX, and my manager is very supportive and I get to talk to Shannon (head of UX and content) and learn what she does.”

Advice for someone coming here?

“Don’t be afraid to share your ideas and ask questions, and you have access to everyone here, so it’s a great place to take advantage of that and to have your voice heard.”

What is it like to talk to customers?

“It feels good to help people and to be able to give them a different experience than they have with other agencies.  It’s important to empathize with each customer, everyone has a unique situation.”

Join our growing team!  

Apply Here

Diversity Builds Successful Teams in Tech

By on August 15th, 2017 in Company News, Culture, Industry Insights

The subject of diversity is a hot topic in leading tech companies today. Many of them would have you believe that cultural and gender diversity is an important subject that they actively promote. Frequently, they use diversity statements and marketing materials to advertise the importance of programs geared towards building diverse teams. All too often, these efforts end up being nothing more than empty words on a page.

While it may sound politically correct to support diversity and inclusion efforts, behind the scenes, many tech leaders dispute how important this work truly is. Throughout the years, I’ve been confronted with executives in leading enterprises who have privately denied the importance of diversity. In each of these situations, I’ve prevailed in making tangible changes that have proven the importance of diversity to the success of a company. As a result of these changes, we closed the gender compensation gap with women employees earning 99.8% of the total compensation of men, as well as increasing the population of minorities in leadership positions by 18% in a caucasian dominated environment.

Obtaining buy-in to adopt diversity from leaders who don’t understand its importance can be tricky and challenging. In my experience, the lack of buy-in is due to one fundamental issue. Most arguments in favor of diversity are usually based on subjective or social opinions. For example, in the following statement, “Diversity is good for companies because of today’s more accepting societal changes,” the subjectivity is undeniable.

The methodology for implementing changes is grounded in facts, but it is also based on the values of a company. I’ve found that when you use company values as a measuring stick in addition to logic and evidence, arguments in support for diversity are much more compelling. Arguing over whether or not diversity is a good or righteous is simply the wrong question to ask. A better one is, “How is the performance of our company linked to diversity?”

Once you ask this question you can begin to define what both “performance” and “diversity” mean in familiar terms. For example, you can define “performance” as KPIs (Key Performance Indicators) i.e. profitability, and market share etc; and “diversity” – as the blending of multiple characteristics of a company’s talent. After doing this, you can connect characteristics to demographics such as gender, ethnicity, race, age, experience, education, and attitude. Finally, after clearly defining “performance” and “diversity” you can point to many leading case studies that substantiate all the benefits of a heterogeneous workplace.

At TrueAccord, we believe that diversity is not just advantageous, but paramount to our success. We’ve experienced firsthand how this work can strengthen a company, especially in the following areas:

 

Innovation

The diversity of thought and expression will help tech companies develop the courage it takes to move from what is familiar to what is different. When you bring people together with different backgrounds, cultures, and perspectives at the early stages of a company, you can seed the importance of fostering inclusion which promotes new ways of thinking as your company grows. The bottom line here is that diverse teams generate creative ideas that will ultimately drive your company’s results, and a company that harnesses that diversity has a much higher chance of success.

Attracting Top-Talent

The rare opportunity to join a multicultural environment in tech is a key selling point when recruiting top-talent in the Bay Area. As a potential employee, first impressions can make or break your decision to join a team, walking into an office and seeing a diverse work force shows you that the company is committed to diversity. Working at a place that truly values this work is incredibly rewarding. The best talent comes in all shapes, sizes, and colors. Harnessing this talent to accomplish your company’s goals will unleash ideas and solutions that will remove many of the roadblocks for those who only hire the same type and class of individual.

Productivity

Hiring diverse teams increases the range of knowledge and skills within that team, as each individual brings knowledge from past experiences to the table. This breadth of collaborative knowledge can be the secret sauce that gives your company the key advantage in a fast-paced, ever-changing industry like tech.

Concrete steps to increase diversity in your company:

#1 Remove unconscious bias during interviews

The recruitment process must support cultural, age, and gender differences at every stage; it’s important that managers are trained to combat the less spoken about unconscious biases they hold. This will curb the unconscious ability for managers to treat qualified candidates unfairly.

At TrueAccord we counteract the unconscious bias by redacting names and education on resumes which directs the focus to practical skills and accomplishments. Interviews are conducted with diverse panelists who focus on competency based questions, putting less importance on factors such as ethnicity, age, gender or the school someone attended.

#2 Make diversity part of your company culture

We’ve found that placing a strong focus on diversity contributes to higher employee engagement and retention rates. This is extremely important as technical roles typically have higher turnover rates.

#3 Implement a zero-tolerance policy for prejudice and install “Collaboration” as a Core Value.

Saying that diversity is part of our identity is a promise we take seriously. We take a zero-tolerance approach towards any negative actions or beliefs related to personal identity.

We also made a commitment to not just accept, but to celebrate our differences. To make this real we have implemented a Diversity Committee with rotating members who regularly serve as a resource to our working community by providing education, information, referrals, advocacy, coordination and support for specific diversity-related events and activities throughout the company.

TrueAccord Culture 

One of the main challenges of managing diversity is the demographic changes in populations. The constantly changing demographic profile of the broader population means that organizations need to develop strategies that will meet the needs and desires of the communities they work within. At TrueAccord, we service all types of people in debt across the US. Our mission is to help consumers in debt by offering options and trust as an alternative to blame and conflict, and it has proven incredibly successful. And because we have a diverse population of employees that reflects the diversity of people we serve, we continue to experience tremendous growth. As of August 2017, we have an almost equal gender divide with 53.85% male and 46.15% female population. Our combined multicultural population consists of 60.29% staff compared to 39.71% caucasian employees. Compared to national leading industry surveys 28% female vs 72% male populations in proprietary software, 25% female vs 75% male populations in Information Technology, we are changing the perception of what populations tech companies employ.

 

While we’ve had and will continue to experience growing pains associated with our significant gains in revenue, we work to overcome obstacles by practicing full transparency when looking back on our mistakes. This type of transparency starts at a grassroots level. We’ve learned that creating feedback loops and cascade meetings works in a culture that incorporates inclusive behaviors. These behaviors extend to performance evaluations, training, and when remediating problems.

By building inclusive communication practices, encouraging differences in opinion, and not tolerating negative attitudes, we continue to increase the diversity of our teams as we scale and grow. Not only are we reinventing an 80-year-old industry through technology and values, we are also redefining what populations in tech companies can do when they are composed of people from different backgrounds, ages, and perspectives.

Debt Collection 101: Where to Begin

By on August 7th, 2017 in Debt Collection, Industry Insights

The heydays of 2015 are over, and investors are looking at business operations and growth before opening up their checkbook for the next round of funding. They are pushing for better margins and cash flow. In the past, you focused on top line growth and knew that there’s another round coming. You can’t do that anymore.

You talk to your CFO and it’s obvious that chargebacks and late payments are a bigger line item than you’d want them to be. You don’t need to be a lender for that. You could have chargebacks from people who regret their purchase (but somehow forget to return the item). Some are on post-paid plans but their cards expire. Some use your product, incur penalties, and never pay them. Simply writing off the debt is not an option.  

Why not do collections in-house? You may decide to try an in-house collections department. Your customer service people aren’t too excited about the new tasks, so they make a few calls and send an email, but no one responds. Those that do pick up the phone are sometimes aggressive and your agents can’t handle them. You realize that collections and customer service are not complimentary job functions and need to be separated. You try to hire a collections professional and are shocked by the cultural mismatch. This isn’t going to work. You’re not going to invest a lot upfront in the hopes of recovering 2% of what’s owed to you.

You decide to work with an outside collection agency. These folks don’t speak your language. They don’t even know what an API is. They outsource their collection activity to Guatemala because that’s how they can make 6 calls per day per customer, cheap. They become defensive when you mention your customers don’t like being called and prefer digital channels like email and text. You want them to care about your brand and customers but their agents make commissions on every dollar collected and if they can’t make their numbers, they get booted. You see where this is going. It’s not going to work.

Here’s the thing: debt collection is part of the business lifecycle, and when implemented correctly, can help you get paid while maintaining your brand and customer engagement. It’s possible to collect and keep your customers satisfied. Collections can use digital channels and a self-service system that gives people the payment flexibility they need, improves your chances of recovery, and reduces the time it takes them to commit to a payment. We’ve seen collection rates as high as 27% for eCommerce companies, because many of your customers who fall behind want to pay. They just needed to be treated correctly – in the same targeted, data driven, UX-first approach that you use for the rest of your product. That’s what we spend a lot of time building.

The Debt Collection Rule is Coming in 2017 – Here’s What to Expect

By on August 7th, 2017 in Compliance, Debt Collection, Industry Insights

The CFPB just announced its 2017 rulemaking agenda. In its message, the CFPB states that it has “decided to issue a proposed rule later in 2017 concerning debt collectors’ communications practices and consumer disclosures.” InsideARM puts the date at September of this year. This is great news for consumers, creditors – and even collectors.

The rule is expected to focus on collector communication practices. Judging by the CFPB’s 2016 outline, that includes clarifications on the use of social media and emails for collections, as well as a cap on weekly contact attempts per account.

Emails and social media are consumers’ preferred channels for communication, even with debt collectors. We expect this rule to open the flood gates on responsible, consumer-centric, and scalable collection practices that will benefit everyone involved. We’ve written extensively on how machine learning based, digital first systems collect better than traditional solutions, and we expect these clarifications to greatly aid in giving consumers what they want.

Contact caps continue the trend of limiting the use of phone calls as means to communicate with consumers in the debt collection process. As we wrote before, the biggest challenge to the debt collection industry is that phone calls are becoming irrelevant. The CFPB is continuing the regulatory trends following consumer preference, and while it’s opening up new communication channels, it’s severely limiting phone calls. We expect this trend to worsen.

This rule is a boon for the collection industry. While it may be challenged by those who focus on getting the most profit out of old school technologies, those in the industry who embrace technology and want to help consumers can’t help but appreciate the trend. The regulator is paving the way towards better user experience, better cost adjusted technologies, and an ability to actually help consumers at scale. Industries like e-commerce, tech and fintech have been very focused on consumer experiences and cannot afford to subject their customers to traditional agency behavior.  And major banks and lenders realize that this revolution is coming, and many of them have already engaged in transforming their vendor network and internal operations to be future facing. This rule is another great step on that path.

Response to the FCC Notice of Inquiry (NOI)

By on July 31st, 2017 in Compliance, Debt Collection, Industry Insights

The FCC recently released a Notice Of Inquiry (NOI) on the topic of on-call authentication, and the debt collection industry is again up in arms about its past, rather than embracing its future. Collectors are having a hard time authenticating consumers’ identity on phone calls, and that leads to a lower number of productive conversations. In a detailed article on InsideARM, Stephanie Eidelman correctly states that “While [the proposal] is not aimed specifically at debt collection, the problem is significant in the industry. The next trick would be to assist in helping the consumer authenticate their identity to a legitimate collector, in a way that eliminates the need to share personal information.” Dear collectors, there are wonderful authentication solutions available to you. Put down that headset, turn off your dialer, and turn your attention to the online world.

Consumer preference is changing. 97% of business calls go unanswered, according to Neustar. Phone calls are real-time interactions, imposing on the consumer’s time and attention. Once consumers pick up, they start from deep suspicion towards the person on the other side, who now has to earn their trust while asking for personal information. It’s a stressful situation, especially for someone paid a commission for collected dollars. Often this devolves into a heated exchange between a stressed consumer and an equally stressed collector. Calls aren’t only bad for reaching consumers; they are bad for engaging them in a meaningful exchange, too.

Emails and digital communication channels provide a superior customer experience. Emails and social media apps are password protected, simplifying the authentication process. If you require added security, many established companies offer real time authentication solutions that keep the consumer engaged with your system. It is easy to quantify and improve the experience to keep consumers engaged, reviewing their options, until they find one that fits. Consumers can choose to engage in times that work for them, rather than times when collectors are available to take their call. As a result, using digital channels significantly cannibalizes the phone channel: on average, TrueAccord makes 5 call attempts to each account over a 90 day placement period, compared with up to 6-10 attempts per day in call center based operations, and still collects better with lower complaint rates.

Calls pose multiple challenges – from operational ones to legal ones. They are costly and complicated. The FCC’s ATDS ruling is disastrous and further limits the efficacy of phone calls. Yet collectors choose to focus on fighting phone-related regulation instead of finding new ways to communicate with consumers. It is starting to look as though some prefer a contact method that consumers think of as harassing and intrusive, because moving to digital communications is simply outside of their comfort zone.

Code Driven Compliance is the Future for Debt Collection

By on July 17th, 2017 in Compliance, Industry Insights, Machine Learning

Debt collection is a highly litigated activity. Compliance personnel and systems budgets are crowding out other investments. It’s appropriate: debt collectors and creditors are often hit by class action lawsuits and government action, leading to huge fines and settlements. Reducing risk is their primary priority. When examined closely, though, the traditional debt collection model attracts numerous compliance issues. The legacy approach is being replaced by  machine learning and digital first systems. These code-controlled systems offer predictable, scalable, and auditable operations that, coupled with best in class user experience, significantly reduce the risk of litigation and regulatory action.

The traditional model invites regulatory scrutiny and lawsuits

Collectors often cite compliance concerns as impediment to adopting new technologies. Lawyers are concerned about TCPA exposure from text messaging, consent requirements for emails, and FDCPA violations when using social media. These concerns are unfounded: text messages can be safely delivered if consent and revocation are properly documented, the CFPB saw no need for consent to email (as reflected by a growing body of opinions, as well as its 2016 rule outline), and social media can be used with restraint. While dragging their feet on evaluating new technologies, compliance departments embrace and perpetuate much bigger risks: the prevalent use of human labor, over reliance on phone calls, and the outdated, fragmented interfaces used by collectors.

Humans are the weakest link in the compliance chain

Traditional wisdom says that only people collect from people. That claim is demonstrably false. People are subject to biases and acting emotionally when interacting with debtors – which is why machine learning based systems collect better than humans. People may be tired, angry, or distracted. They can be baited into violating the FDCPA by a ill-meaning debtor. The prevalent commission-based compensation model, a broken and outdated model for collections, puts them in odds with debtors whenever they interact. Human beings just cannot do error-free work, no matter how trained or experienced they are.

Keeping appropriate staffing levels is another challenge for collection teams. Large market participants report 75-100% annual turnover rates (per the CFPB’s operational survey), requiring constant hiring of collection staff. Training and overseeing these new people is a daunting task, especially with the ever changing case law and legislative landscape in the collection space. Providing an efficient and fully compliant collection experience while relying on new and untrained collectors is almost impossible.

Phone calls are a dying communication method

Consumer preference is shifting away from phone calls, but phone call compliance would have been difficult even if that wasn’t the case. Calls are a compliance liability due to their frequency, their real-time nature, and the overall regulatory sentiment towards them.

Collection calls must be frequent to reach consumers. On days when an agent works an account, they may attempt to contact the consumer 4-6 times, often as frequently as 10 times per day. Consumers aren’t picking up the phone, so agents need to make more call attempts to try and reach them.   While most states, and the FDCPA, don’t limit call frequency, high frequency of calls often leads to complaints and lawsuits alleging harassment. Collector take this huge risk because calling is the only tool they understand.

Collection calls are also real-time. No matter how elaborate call scripts are and how experienced collectors may be, it is impossible to completely control the development of any individual call. Voice analytics software is limited, unable to identify most baiting and escalation issues. Real time monitoring of all calls by supervisors is financially implausible. Collection agencies are forced to settle for the best training possible, clear escalation paths for collectors whose calls go badly, and hoping for the best. Realistically, when making a large volume of calls, every day will have some potential violation.

Finally, regulation has been working against phone calls for the past few years. The FCC’s ruling limiting the use of ATDS has been devastating, and expecting it to be completely undone by the new commissioner is a pipe dream – government is not debt collectors’ friend. States like West Virginia and Massachusetts have enacted call frequency limitations, and the CFPB’s new rule outline includes a 6-times-per-week limit on call attempts. All signs point to a future where phone calls cannot plausibly be the main channel for collecting debt with any semblance of compliance.

Code driven compliance is here, and it’s a big step forward

Code driven compliance gives us complete control on what actions can be triggered by our system. It’s one of the components in Heartbeat, our machine learning-based, digital first collection platform. Heartbeat is a leap forward in debt collection, and its compliance advantages are many: from better user experience to perfect auditability.

Best in class user experience in debt collection is a compliance advantage

Many if not most of debt collection lawsuits hang on a technicality. A word is arguably missing or written in a debatable way. It’s unclear whether 8 calls or 9 calls constitute harassment. Often, consumers don’t resort to lawyers because they know for a fact they have been wronged – it is often not clear that they have been – but because their experience with the collector has been bad enough to push them to seek defence or retribution. Great user experience is therefore not only a way to improve the creditor’s brand perception and returns, but also a way to reduce the rate of complaints and lawsuits. TrueAccord’s Heartbeat system attempts to contact consumers an average of 3 times per week, compared to 4-6 times a day for traditional agencies. That, paired with best in class web and mobile experience and a helpful customer service department, significantly reduces consumers’ desire to sue for, or complain about, ambiguous technicalities.

Consumers get a consolidated account page showing all their options

Since more than 90% of Heartbeat’s interactions with the consumer do not involve a human collector, human beings are only needed for a fraction of the work. TrueAccord is able to hire skilled workers and pay them a living wage, with no commission component. Knowing that they will earn a good salary working for a technology startup reduces any incentive our team members would have had to fight with or harass consumers. That, in turn, contributes to great user experience and reduces compliance risk.

Pre-approved content and an integrated system eliminate human error

Human error is the biggest challenge for compliance departments. Collectors today need to navigate multiple systems to call, negotiate with, and collect payments from consumers. Updating the results of a call is often a complex process, requiring yet another system. Many requests to unsubscribe numbers, cease and desist communications, or simply to provide debt verification are lost and lead to complaints. This fragmented process is extremely tedious and time consuming, and inherently flawed. Letting collectors write their own emails and text messages is too much risk – something that will surely lead to violations on a daily basis.

TrueAccord’s content approval console

Heartbeat takes a code controlled approach to communications. Every outgoing communication is pre-written, then reviewed and pre-approved by TrueAccord’s legal team. Every email, text, web page and letter have to pass TrueAccord’s content guidelines driven by law, policy and procedures, including required disclosures and forbidding certain words and phrases in subject lines, or in the body of communications. Our clients’ legal and content team are also involved in commenting on our procedures as well as specific content items, to make sure we fit each company’s risk tolerance. Heartbeat will only send text messages to numbers that it knows it has express consent to text, and that have gone through an ownership check within a defined time period. Even when collectors respond to inbound consumer emails, they use pre-written replies that then direct Heartbeat how to proceed in serving the consumer. The decision to proactively communicate is strictly based on Heartbeat logic, not on collector whims; collectors cannot decide to contact consumers whenever they see fit.

After contacting consumers, the system monitors their response. Consumers can easily opt out of communications, by replying to a text message or by clicking a link in every email that lets them easily unsubscribe from future email communications. Every email and every payment page contain a link that lets consumers ask for debt verification via a few simple online steps instead of a cumbersome and mail-based process. Every interaction is designed to give consumers an opportunity to ask for more information or limit communications to their preferred channel. Though easy to dismiss as an invitation for abuse, these options increase consumer engagement and result in overall better collections – while significantly reducing complaints about continued communications and missing documentation. These two categories have consistently been the top reasons for filing CFPB disputes ever since its dispute portal was made public.

The compliance firewall: enforcing compliance at scale

Human collectors are expected to remember dozens, maybe hundreds of compliance laws and regulations as well as creditor-imposed rules. It’s an impossible task, greatly simplified by Heartbeat’s Compliance Firewall. Since it controls all contact decisions by code, Heartbeat can enforce its compliance policy at scale on every interaction without needing to train human collectors. Contact timing or frequency, matching content to the right stage in a consumer’s process or preventing the use of unsubscribed contact methods, even making sure that a consumer doesn’t get a payment offer that the creditor didn’t approve – all are controlled by the Compliance Checker. Any attempted action outside of its well defined policy is dropped. Since it’s code controlled, it cannot forget to check the time and call a consumer after 9pm or before 8am.

The Compliance Firewall also allows updates to policies and procedures. Every new update can be implemented with accuracy within days, once the appropriate code is written. By taking judgement away from the collector and subjecting all contact decisions to a data-based, code-controlled system, Heartbeat makes the optimal decision for consumer experience and driving payments, without harassing the consumer or violating the myriad of restrictions that govern debt collection.

The easiest system to audit

Compliance requires tight monitoring, and creditors audit a large sample of collection activities by their vendors. With so many voice calls, even if they are all recorded, complete and accurate audits are impossible. Auditors need to sample cases and hope to find the right patterns, or employ a large and expensive team for sufficient coverage. Heartbeat eliminates almost 95% of phone calls (typically attempting to reach the consumer 3-5 times over a 90 day period), instead focusing on written communication. Back and forth written interactions are easier to capture, store, and search. The system also saves consumers’ browsing pattern on the website and their interactions with the content they receive. It’s easy to track consumer behavior and how the system responded to it, as well as why it made a specific decision. Code controlled compliance means that decisions are easy to replicate and trace back in case they’re questioned.

A readout from TrueAccord’s event-based audit trail

TrueAccord’s system also has an audit interface for creditor audits. Compliance staff can easily search for accounts and review all collection activity – including recorded calls, emails, and every other contact. It’s a much easier approach to compliance and controls than an unwieldy excel file or PDFs dropped in an FTP folder. TrueAccord’s data retention and tracking of consumer behavior provide a fuller snapshot of Heartbeat’s collection decisions and how consumers reacted to them.

Code driven compliance is the future

We examined the inherent risks in traditional collection activities and how sticking to the phone as the leading collection tool in a call center environment creates more risks than rewards. Then, we dove into how code controlled compliance offers predictable, pre-approved, and consistent collection strategies that are easy to audit and understand. The coming years will see more and more creditors and collectors move to these machine learning based systems, as they demonstrate dominance in returns and compliance. It’s time for risk averse compliance departments to realize that they are putting businesses at risk by sticking to their phone-based roots, and look beyond tradition. A whole world of mature, stable and trustworthy technologies awaits.