Category: Industry Insights

TrueAccord’s Recent Litigation Win: Email Is Always Convenient

By on November 22nd, 2024 in Industry Insights

TrueAccord is at the forefront of defending litigation related to digital communications in debt collection and its recent victory in the Southern District of Florida is a resounding victory for digital channels in our industry.

In Quinn-Davis v. TrueAccord, the court grappled with the concept of timing in order to figure out when an email is considered inconvenient under both the Federal Debt Collection Practices Act (FDCPA) and the Florida Debt Collection Practices Act (FCCPA). In this case, TrueAccord sent the email at 8:23pm, which is considered a convenient time by both statutes. The plaintiff’s email service provider delivered the email into plaintiff’s inbox at 10:14pm, and the consumer opened the email the following day at 11:44am. The court found no violation of the FDCPA or the FCCPA and granted summary judgment in TrueAccord’s favor.

The FDCPA and FCCPA Prohibitions on Inconvenient Time

To reach its decision, the Court evaluated the inconvenient time provisions of the two statutes. First, the Court analyzed the FDCPA’s provision, breaking it down into three principles:

  1. The basic prohibition: A debt collector may not “communicate with a consumer” in connection with any debt collection at (i) any unusual time or place, or (ii) a time or place known or which should be known to be inconvenient to the consumer. 
  1. The safe harbor: In the absence of the debt collector’s knowledge of circumstances to the contrary, a debt collector shall assume that communicating with a consumer between 8:00 a.m. and 9:00 p.m. (at the consumer’s location) is convenient (and therefore does not trigger liability). 
  1. The prior consent exemption: If the “prior consent of the consumer” is given “directly to the debt collector,” then the debt collector can engage in the activity described in #1 above, regardless of the debt collector’s knowledge or assumptions of the consumer’s communication preferences. 

–See 15 U.S.C. § 1692c(a)(1).

The Court explained that the FCCPA uses similar language to the FDCPA, quoting the statute:

In collecting consumer debts no person shall: … Communicate with the debtor between the hours of 9 p.m. and 8 a.m. in the debtor’s time zone without the prior consent of the debtor.” Fla. Stat. Ann. § 559.72(17) (emphasis added).

The Court noted that, since this case turned on the interpretation of “communicate with,” it did not have to “parse” the “prior consent” exception language. Applying the facts to these two statutes, the court found no violation of law under either—the first published decision relating to email and inconvenient times.

The Court’s Decision: Email, By Its Silent Nature, Is Never Inconvenient Like Noisy Calls

The decision starts with an eye-catching quote:

“If a tree falls in the forest and no one else is around to hear it, does it make a sound?” This case poses a modern variation of that old chestnut, with a tip-of-the-cap to our elected representatives in Washington, D.C. and Tallahassee…

The court cites its authority under the recent U.S. Supreme Court decision Loper-Bright Enterprises v. Raimondo to reject the CFPB’s interpretation of when an email is considered inconvenient in Regulation F, discussed further below. In its own interpretation, the court found that the consumer opened and read the email at 11:44am, which is a presumably convenient time under both statutes.

The court explicitly stated that it did not take into consideration facts about whether the timing of the email was inconvenient because no evidence was presented on it. However, the court said:

So, what is a prohibited e-mail communication under the FDCPA? When precisely does liability attach? If a debt collector sends an e-mail after 9:00 p.m. and the consumer opens and reads it at 9:00 a.m. the following day, does that violate the FDCPA? What if the debt collector sends an e-mail before 9:00 p.m. but the consumer reads it at midnight? Liable? Clearly, the FDCPA’s safe harbor was aimed at protecting consumers from after-hours noisy telephone rings—not e-mails sitting in one’s e-mail box (silently) overnight. (Emphasis added.)

By this language, the Court suggests that even an email sent after 9:00pm may not be a violation of the inconvenient time prohibition. In this case, the plaintiff opened the email over 13 hours after it was delivered into their inbox, indicating the consumer waited to read it until it was convenient for them.

Ultimately, an email is convenient whenever the consumer opens it because that is when they chose to do so. TrueAccord knows this to be true based on our email communications with millions of consumers. Our own engagement data shows that 25% of consumers engage with emails after 9:00 pm and before 8:00 am. The timing between when an email is sent, delivered, and opened, similar to physical letters, may vary widely from consumer to consumer based on their own choices.

The Court Refused to Follow the CFPB’s Interpretation of the FDCPA

It is important to recognize that in reaching this decision, the Court declined to follow the CFPB’s guidance. In Regulation F, the CFPB spelled out its official interpretation that the time an email is sent, not delivered, is used to determine whether the communication was sent during an inconvenient time. See 12 C.F.R. Part 1006.6(b)(1)(i)(1).

Citing both the Supreme Court Loper decision (and the original, landmark Supreme Court decision in Marbury), the Court stated:

While the CFPB interpretation may have some appeal (on policy grounds), I am neither bound by it nor required to defer to it. See generally Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024) (overruling Chevron USA, Inc. v. Nat’l Res. Defense Council, 467 U.S. 837 (1984)). “It is emphatically the province and duty of the judicial department to say what the law is.” Loper, 144 S.Ct. at 2257 (citing Marbury v. Madison, 1 Cranch 137, 177, 2 L.Ed. 60 (1803)).

Based on the plain language of the FDCPA, the Court independently concluded that a debt collector must “actually transmit or transfer information to another person in order to communicate with a consumer.” Notably, in reaching this conclusion, the Court pointed out what all of us already know because we use email every day, stating:

You don’t need to be a Ph.D. in computer science to take judicial notice of the basic nature of e-mail communication. Hundreds of millions of Americans use e-mail all the time.

This decision does not require debt collectors who set up their email policies and practices based on the CFPB’s Regulation F guidance to change their practices. As the Court noted, sending proactive, debt collection emails during the presumptively convenient hours of 8:00am to 9:00pm may be “more protective of consumers in many cases.” Just like sending physical letters, the time when a consumer chooses to read the email is outside of a debt collector’s control and fully within the control of the consumer. If the consumer chooses to read it late at night or 2 days later at noon, that is the consumer’s choice and their preferred time to read that message. Therefore, it remains a best practice for compliance with the plain language of the FDCPA and similar state laws like the FCCPA, to send proactive, debt collection emails during presumptively convenient times.

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Note: This blog post is for informational purposes only and does not constitute legal advice. It does not create an attorney-client relationship. Readers should consult their own counsel for advice regarding their specific situation.

Q3 Industry Insights: Inflation and Interest Rates Drop, Christmas Comes Early

By on October 22nd, 2024 in Compliance, Customer Experience, Industry Insights

The big inflation situation plaguing the U.S. for the past three years seems to be coming to an end, and it could be that American consumers are partially to thank. Tired of paying higher prices, consumers increasingly turned to cheaper alternatives, bargain hunted or simply avoided items they found too expensive, pressuring retailers to accommodate them or lose their business. That’s not to say Americans have stopped spending altogether—the economy continues to expand and people continue to struggle against inflated prices for necessities across the board, often still turning to credit cards to make ends meet.

With consumers setting the demand amidst elevated prices and inflation declining slowly, retailers have gotten an even earlier jump on holiday promotions this year in the hopes of boosting sales in a price-wary environment. Spreading holiday expenses out over a longer period of time may ease the financial burden slightly, but the cumulative dollars spent will still weigh heavily on consumer finances for Q4 and rolling into 2025. The National Retail Federation is forecasting that winter holiday spending is expected to grow between 2.5% and 3.5% over last year, with a total reaching between $979.5 billion and $989 billion.

We are starting to feel an economic shift, but what does this all mean and what’s the outlook for the end of the year? Read on for our take on what’s impacting consumer finances, how consumers are reacting and what else you should be considering as it relates to debt collection today.

What’s Impacting Consumers?

While not the straight line decline economists would like to see, the September results show that inflation is slowly and steadily easing back to the Federal Reserve’s 2% target. After several months of decreasing inflation and amid slowing job gains, the Fed in September announced the first in a series of interest rate cuts, slashing the federal funds rate by 1/2 percentage point to 4.75-5%. Federal Reserve Chair Jerome Powell indicated that more interest rate cuts are in the plans but they would come at a slower pace, likely in quarter-point increments, intended to support a still-healthy economy and a soft landing. 

The rate cut plans have been made possible by consistently declining inflation. The Consumer Price Index rose just 2.4% in September from last year, down from 2.5% in August, showing the smallest annual rise since February 2021. Core prices, which exclude the more volatile food and energy costs, remained elevated in September, due in part to rising costs for medical care, clothing, auto insurance and airline fares. But apartment rental prices grew more slowly last month, a sign that housing inflation is finally cooling and foreshadowing a long-awaited development that would provide relief to many consumers.

The September jobs report supported the economic optimism by adding a whopping 254,000 jobs, far exceeding economists’ expectations of 140,000. The unemployment rate lowered to 4.1%, below projections of remaining steady at 4.2%. The government has also reported that the economy expanded at a solid 3% annual rate Q2, with growth expected to continue at a similar pace in Q3. This combination of downward trending interest rates and unemployment plus an expanding economy is great news for consumers and businesses alike, and can’t come soon enough for many financially strained Americans.

Coming out of Q2, total household debt rose by $109 billion to reach $17.80 trillion, according to the latest Quarterly Report on Household Debt and Credit. This increase showed up across debt types: mortgage balances were up $77 billion to reach $12.52 trillion, auto loans increased by $10 billion to reach $1.63 trillion and credit card balances increased by $27 billion to reach $1.14 trillion. 

Unsurprisingly, delinquency and charge-off rates ticked up as consumers struggled against still relatively high prices and interest rates. In mid-September, shares of consumer-lending companies slid after executives raised warnings about lower-income borrowers who are struggling to make payments. Delinquency transition rates for credit cards, auto loans and mortgages all increased slightly, with a steeper increase in flow to serious delinquency for credit cards, up more than 2% over last year from 5.08% to 7.18%. This kind of delinquency can be especially difficult for consumers to recover from given the record-high credit card rates many are stuck with.

While still low by historical standards, the mortgage delinquency rate was up 3 basis points in Q2 from the first quarter of 2024 and up 60 basis points from one year ago. The delinquency rate for mortgage loans increased to a seasonally adjusted rate of 3.97% at the end of Q2, according to the Mortgage Bankers Association’s (MBA) National Delinquency Survey, an increase that corresponded with a rise in unemployment and showed up across all product types.

For those with student loans, September marked the end of the ‘on-ramp’ to resuming payments, which was the set period of time that allowed financially vulnerable borrowers who missed payments during the first 12 months not to be considered delinquent, reported to credit bureaus, placed in default, or referred to debt collection agencies. However, the grace period is over and anyone who doesn’t resume making student loan payments in October risks a hit to their credit score—we will see these delinquencies reported in Q4.

Financial Protection for Consumers Across the Board

The Consumer Financial Protection Bureau (CFPB) continued with a high level of activity through the summer. Along with taking action against more than a handful of financial services companies in the name of consumer protection, the agency made headway on myriad other issues.

To kick off Q3, the CFPB published Supervisory Highlights sharing key findings from recent examinations of auto and student loan servicing companies, debt collectors and other financial services providers that found loan servicing failures, illegal debt collection practices and issues with medical payment products. The report also highlighted consumer complaints about medical payment products and identified concerns with providers preventing access to deposit and prepaid account funds.

Then, the CFPB and five other agencies issued a final rule on automated valuation models. The agencies, including the OCC, FRB, FDIC, NCUA, and FHA designed the rule to help ensure credibility and integrity of models used in valuations for certain housing mortgages. The rule requires adoption of compliance management systems to ensure a high level of confidence in estimates, protect against data manipulation, avoid conflicts of interest, randomly test and review the processes and comply with nondiscrimination laws.

Next, the CFPB joined several other federal financial regulatory agencies to propose a rule to establish data standards to promote “interoperability” of financial regulatory data across the agencies. The proposal would establish data standards for identifiers of legal entities and other common identifiers.

Also in August, the CFPB responded to the U.S. Treasury’s request for information on the use of artificial intelligence in the financial services sector. The CFPB emphasized that regulators have a legal mandate to ensure that existing rules are enforced for all technologies, including new technologies like artificial intelligence (AI) and its subtypes. It’s clear that the CFPB has an interest in how those technologies are used and what the consumer impact may be.

In September, the bureau issued its annual report on debt collection, which highlighted aggressive and illegal practices in the collection of medical debt and rental debt. The report focused on improperly inflated rental debt amounts and on debt collectors’ attempts to collect medical bills already satisfied by financial assistance programs, also noting that many medical bills from low-income consumers do not get addressed by financial assistance in the first place.

Finally, the CFPB published guidance to help federal and state consumer protection enforcers stop banks from charging overdraft fees without having proof they obtained customers’ consent. Under the Electronic Fund Transfer Act, banks cannot charge overdraft fees on ATM and one-time debit card transactions unless consumers have affirmatively opted in.

Disjointed Consumer Sentiment Weighs Heavy

A September Consumer Survey of Expectations found that Americans anticipated higher inflation over the longer run as their expectations of credit turbulence rose to the highest level since April 2020, according to the Federal Reserve Bank of New York. While perceptions and expectations for credit access improved, the expected credit delinquency rates rose again and hit the highest level in more than four years. According to the survey, the average expected probability of missing a debt payment over the next three months rose for a fourth straight month to 14.2%, up from 13.6% in August, suggesting some Americans are concerned with their ability to manage their borrowing. 

Despite inflation easing, consumers perceive that the costs of everyday items are on the rise. According to the latest report from PYMNTS Intelligence, which tracks the percent of consumers living paycheck-to-paycheck, 70% of all consumers surveyed said their income has not kept up with inflation. This feeling is stronger for paycheck-to-paycheck consumers, with 77% of those struggling to pay bills on time reporting that their income hasn’t kept up with rising costs. Even for those not living paycheck to paycheck, 61% shared this concerning sentiment. As a result, consumers are buying cheaper or lesser quality alternatives, if they’re buying at all.

Prior to the September interest rate cuts, the Conference Board’s Consumer Confidence Index showed consumer confidence plunging to the most pessimistic economic outlook since 2021, based on a weaker job market and a high cost of living. Americans reported being anxious ahead of the upcoming election and assessments of current and future business conditions and labor market conditions turned negative.

However, following the Fed’s rate cut announcement, another report from the University of Michigan’s sentiment index showed a rise in late September, reaching a five-month high on more optimism about the economy. Consumer expectations for price increases dropped simultaneously with more expectations for declining borrowing costs in the coming year. Consumer sentiments on their finances directly impact their spending and payment behaviors, so understanding where they stand can inform a better debt collection approach. 

What Does This Mean for Debt Collection?

You’ve heard of Christmas in July, but Christmas in September? With the holiday shopping season starting earlier and in the midst of a high-stakes election, consumers will continue to prioritize expenses and spending based on their current financial outlook, which hasn’t yet caught up with the optimism showing up in the overall economy. The unknowns of what happens post-election along with the delayed impact of lower interest rates and inflation on spending leave the outcome for consumer finances uncertain. Delinquencies continue to persist and it may be some time before the benefits of a friendlier economy show up in consumers’ bank accounts. For companies looking to recover delinquent funds now, understanding how, when and in what way to engage consumers can increase recovery success. For lenders and collectors, here are some things to consider for 2025 planning:

• Self-serve = more repayment. For both businesses and consumers, reducing the need to engage directly with human agents to make payments or access account information saves time and resources. Solutions like self-serve portals represent a shift towards greater consumer control over their financial health, providing an efficient way for individuals to address and manage their finances—and debts specifically—on their own terms.

• Omnichannel or bust. If your business relies solely on one channel for customer communications, it’s time to evolve. Utilizing a combination of calling, emailing, text messaging and even self-serve online portals is the preferred experience for 9 out of 10 customers. And it’s not just beneficial for consumers–the omnichannel approach has been shown to increase payment arrangements by as much as 40%!

• Keep an eye on compliance (or make sure your debt collector does). The regulatory landscape will continue to change, especially post-election. Your risk and success hinges on how well you can keep up with the changes, so having someone responsible for monitoring and tweaking your strategy is critical.

SOURCES:

The TrueAccord Difference for a Better Self-Serve Consumer Experience

By on October 18th, 2024 in Customer Experience, Industry Insights, Machine Learning, Product and Technology, User Experience

While many financial service institutions can offer basic payment portals, these are often limited when it comes to collecting on delinquent accounts. TrueAccord delivers a robust difference.

Self-serve options should be a key part of any collections operation. In fact, research from McKinsey found that consumers who digitally self-serve resolve their debts at higher rates, are significantly more likely to pay in full, and report higher levels of customer satisfaction than consumers who pay via a collection call.

At TrueAccord, we provide more than a basic payment portal—the power of our self-serve solutions gives your business and your customers better control over the repayment process. TrueAccord’s self-serve portal delivers less friction for delinquent consumers ready to manage their debt, while your organization determines the extent of account details to display, what flexible payment options you’d like to provide, and more.

Let’s look at how TrueAccord provides a superior consumer experience and better bottom-line results for your business through our self-serve portal and solutions.

Why Offer Self-Serve Options on Top of Traditional Collection Methods?

Two of the most prominent use cases for deploying self-serve channels are consumer preference and compliance—and both are success stories for TrueAccord.

The numbers cannot be ignored: 98% of delinquent consumers serviced by TrueAccord resolve their debt without any human interaction, which in turn saves time, resources, and headcount. When asked why they pay bills online, three in 10 consumer survey respondents said they like the flexibility to pay whenever and wherever they want—a convenience traditional call-and-collect methods cannot extend to consumers due to FDCPA’s “Inconvenient Times” rule under Regulation F.

The “Inconvenient Times” rule prohibits calls to consumers before 8 a.m. or after 9 p.m. in the consumer’s local time zone, because calls made during those times are presumed inconvenient. But self-serve options put the power in the consumer’s hand 24/7. At TrueAccord, 29% of online payments are made outside of traditional FDCPA hours.

Self-Serve Success with Advanced Machine Learning and Omnichannel Engagement

Does your digital debt collection outreach strategy extend beyond email or SMS? A true omnichannel approach goes further to interweave self-serve options—and TrueAccord delivers.

Whether via email, text message, or even physical letters, there are several ways TrueAccord reaches consumers in debt collection and empower them to take charge of their repayment journey through the self-serve portal.

And even if the first engagement attempt is unsuccessful, HeartBeat—TrueAccord’s patented machine learning decision-engine—will adjust communication cadence, content, and even channel dynamically.

Studies show that 54% of consumers expect their financial provider to leverage the data they have about them to personalize their experience, so HeartBeat looks at individual account characteristics—like debt type, creditor, balance size, age of debt, etc.—and selects a message (written by experienced debt collection content creators) based on previous interactions with consumers that have similar characteristics. Thanks to our 35 million consumer interactions collected, HeartBeat drives both the optimal engagement and repayment rates while working within both our client’s guidelines and regulatory requirements.

Want to take an even deeper dive into the consumer experience-side of TrueAccord’s self-serve portal? Download our free eBook for more details and a visual walkthrough of the consumer experience when using our portal here»»

What Do TrueAccord Consumers Have to Say?

Don’t take our word for it—read testimonials and feedback from real consumers who have resolved their delinquent accounts through TrueAccord’s self-serve portal:

  • “This was a great experience for me. The portal was so easy to operate quickly and easily. Thank you.”
  • “Easiest to work with, never had to speak with a representative, was able to fully manage and pay off the account via their online portal.”
  • “I appreciated the zero harassment, easy portal interface. I have been stressed about this for a while, hardship came up, but you made it easy and less stressful to take care of.”
  • “Thank you for being patient and for having a portal that makes it easy to make the payment without filling out a bunch of stuff and having to make an account.”
  • “I appreciate you notifying me via email and having a great online payment portal. It made the process really easy.”

Ready to Get Started?

Empower consumers with a self-serve experience—and collect faster from happier people. Schedule a consultation and get set for a live demo of the TrueAccord self-serve portal»»

Sources:

The Low Friction Way For Consumers to Repay: Self-Serve Options for Debt Collection

By on October 7th, 2024 in Compliance, Customer Experience, Industry Insights, Machine Learning, Product and Technology, User Experience

After months of inflation woes, both economists and consumers are starting to see a glimpse of optimism.In the first interest rate cut since the early days of the Covid pandemic, the Federal Reserve announced in September 2024 that it is slicing half a percentage point off benchmark rates. So it’s not surprising that Americans are getting more confident that inflation is cooling off, but optimism for the U.S. economy doesn’t extend to personal finances—consumer expectations for going delinquent on their debt in the next three months hit their highest level since the start of the pandemic.

And the share of severely delinquent credit card debt rose to 10.7% during the first quarter of 2024, according to the Federal Reserve Bank of New York, compared to just 8.2% of credit card debt more than 90 days overdue in 2023.

But better customer engagement strategies can help businesses recover more debt—and self-serve portals are an empowering way to get consumers back on track.

What is a “self-serve portal” in financial services and collections?

In the financial services sector, a self-service or self-serve portal is a secure online platform or application designed to empower consumers to make payments and, ideally, allow them to manage their accounts and payment terms independently (although not all portals offer the same functionality). Self-serve portals aim to grant customers the ability to manage their finances without the help of a service representative.

For both businesses and consumers, reducing the need to engage directly with human agents to make payments or access account information saves time and resources. Overall, these self-service solutions represent a shift towards greater consumer control over their financial health, providing an efficient way for individuals to address and manage their finances—and debts specifically—on their own terms.

What are the benefits of offering self-service options in debt collection?

Similar to any other financial institution or ecommerce business, self-service portals in collections intend to foster a sense of autonomy for the delinquent consumer to manage their debt without the pressure or inconvenience of interacting with a call center agent. Besides creating a more preferred experience for the consumer, organizations needing to recoup funds will reap several benefits by providing self-serve options as well:

Cost Savings:
In today’s digital world, call centers or full-time employees (FTEs) dedicated to late-stage collections have proven to be an expensive and less effective path for debt recovery. Employees often spend a significant amount of time arranging repayment plans, providing account details, and processing payments—and that’s if the consumer actually answers the collector’s call. So when it comes to cost savings, just consider this: the average cost of a contact center call is $8.01, which is 80x more expensive than a self-service interaction.

Scalability:
Unlike human agents who can physically only make a certain number of calls per day and are legally only allowed to call consumers during convenient hours (as defined by Regulation F), self-serve portals are available to consumers 24/7. These platforms can handle any number of collection cases at any time of day without compromising user experience, making it easy to scale your capacity as delinquency volumes rise—no additional headcount required.

Compliance:
Non-compliance can be costly in the collection landscape heavily regulated by the Consumer Financial Protection Bureau (CFPB). Whether partnering with a third party or training FTEs, the risk of human error resulting in compliance violations is easily mitigated with digital self-serve solutions that have compliance controls built in—but this does require due diligence on the business or lenders’ part to ask and verify that the solution is keeping up with all necessary regulation and industry security standards.

Frictionless Consumer Experience:
Surveys have found that consumers both prefer and want more self-serve options to repay, but that is just the tip of the iceberg of what consumer preferences can mean for your recovery and resolution rates. Research from McKinsey found consumers who digitally self-serve (versus consumers who pay via a collection call):

  • Resolve their debts at higher rates 
  • Significantly more likely to pay in full 
  • Report higher levels of customer satisfaction

Proven Success with TrueAccord’s Self-Serve Portal

While many financial service institutions already offer basic payment portals, these are often limited when it comes to collecting on delinquent accounts. And traditional call centers typically cannot provide self-serve options, even if they can offer other digital options like email or SMS for consumer outreach.

But TrueAccord provides more than a simple payment portal—the power of our self-serve solutions gives your business and your consumers better control over the repayment process for better results.

TrueAccord delivers less friction and frustration for delinquent consumers ready to manage their debt, while your organization determines the extent of account details to display, what flexible payment options you’d like to provide, and more.

In fact, 98% of delinquent consumers serviced by TrueAccord resolve their debt without any human interaction, with 29% of online payments made outside of traditional FDCPA hours—saving time, resources, and headcount while meeting consumer preferences compliantly under Reg F’s inconvenient time rule and beyond.

Want to take a peek at TrueAccord’s Self-Serve Portal? Download our free eBook for more details and a visual walkthrough of the consumer experience when using our portal here»»

Ready to see a demo in action and learn more about all of TrueAccord’s omnichannel, machine-learning powered collections? Schedule a consultation today»»

Sources:

Understanding the Consumer Spending Split and How to Recover More Across the Divide

By on July 24th, 2024 in Customer Experience, Industry Insights, Machine Learning, User Experience

It’s becoming a familiar headline: US household debt keeps climbing and delinquency rates keep rising. According to the Federal Reserve Bank of New York’s Quarterly Report on Household Debt and Credit, household debt rose to $17.69 trillion in the first quarter of 2024. The report showed 6.9% of credit card debt transitioned to serious delinquency in the first quarter, with approximately 4.8% of consumers holding some debt in third-party collections.

Overall, 77% of American households have at least some type of debt, but that debt isn’t evenly distributed—and consumer spending habits can vary just as much depending on income level.

Understanding the split in consumer spending and its impact on household debt—and in turn, collections—is critical for today’s debt recovery strategies. While across the board debt may be climbing and delinquencies rising, your consumer engagement approach and communications to secure repayment cannot be one-size-fits-all for all consumers.

What is the Consumer Spending Divide?

Spending divide. Split-spending patterns. A tale of two consumers. Two-speed economy…all of these naming conventions describe the widening gap between income levels, spending habits, and inevitably types of debt accumulated.

While the last few years showed consistent spending rates across all income groups as a result of pandemic-era benefits, savings surplus, and wage growth, this is no longer the case. More recent data has revealed that as pandemic savings declined at the same time as both inflation and interest rates increased, lower-income households are becoming more financially strained while higher-income households are mostly unaffected.

Today, we see more affluent consumers continue to spend at consistent rates, while more middle- and lower-income consumers’ personal disposable income has not kept pace with rising prices and as a result, these households have become more indebted.

Even when there is a spending uptick in the lower-income sector, as seen in April 2024, what these consumers are spending on and how they are paying for it is still quite different from their higher-income counterparts. These spending patterns show that lower-earning consumers are putting more everyday bills on credit cards—and in turn, credit card delinquencies and charge-offs for these consumers are returning to their pre-pandemic levels faster than other groups.

Not surprisingly, the ripple effect of this deepening income-level divide impacts consumer sentiment along with spending. While surveys from June 2023 had shown similar levels of consumer sentiment between bottom-third earners and top-level earners, today higher-income households report a much more positive outlook compared to many lower earners who report feeling less confident in their own household finances.

And yet, 40% of consumers (across the divide) have expressed an intent to splurge over the summer months—so what different variations of delinquencies can we expect between the split of spenders? And how can businesses differentiate their approach to collections to more effectively recover debt faster?

How Does the Divide Impact Delinquencies?

Let’s start with the first question: what different types of debt are each income sector accumulating today?

Higher-income consumers: non-essentials and luxuries like travel, vacations, hotels, resorts, amusement parks
Surveys show that higher-income households are more optimistic about their ability to take trips and spend on luxuries like full-service hotels and resorts—in fact, 74% of respondents with annual household incomes of $100,000 or more plan to take a summer vacation and, across income levels, 36% anticipate taking on debt to pay for it.

We can even put a microscope to this ‘YOLO’ attitude towards spending on experiences by looking at Disney amusement parks. Surveys find:

  • 45% of parents take on debt for Disney vacations
  • $1,983 is the average amount of debt for those parents
  • 75% report that their Disney trip did or would take six months or less to pay off
  • Total respondents who went into debt during a Disney trip also increased 33% from a 2022 survey

Lower-income consumers: essentials like rent, utilities, everyday necessities
Conversely, the delinquencies for lower-income households start at home: 25% of low-income renters (defined by a Community Solutions survey as those with an annual income of less than $50,000) are 4-7 months behind on rent. And the New York Fed reported 57% of households are rent burdened in low-income areas, where they pay more than 30% of their monthly income on rent.

Even with wage gains over the last several years, 40% of consumers say they earn insufficient incomes and struggle to keep up with inflation and interest rates. And with approximately 75% of low-income households reporting living paycheck-to-paycheck, to bridge the gap there is an increasing reliance on credit cards to cover bills, so it is not surprising these consumers are falling behind on their credit card payments.

The spending divide leads to a divide on what consumers are going into delinquency for—so what’s the best way to engage and secure repayment when consumers’ financial situations and outlooks are so split?

How Can You Recover More Across Each Side of the Divide?

Regardless of where your customers fall in the divide, businesses must face facts: overall delinquent balances increased by 3.46% in June 2024 and then again in July by 0.51%. This paired with the fact that 1.11% of consumer accounts rolled into higher stages of delinquency marks an uptick in the roll rate in June compared to the improvement (decreases) seen in the past several months.

But with delinquency rates continuing to rise, it’s important to tailor your recovery approach to each consumer you seek to collect from with customized, omnichannel engagement.

A successful collections strategy goes beyond the simplified “tale of two consumers” and actually engages with individuals uniquely with the right message delivered through the right channel at the right time for them.

While getting payment reminders is beneficial for consumers across the divide, hovering between roughly 40% to 50% from the under $50,000 cohort all the way to the $100,000 and above bracket, the preference for how these reminders are sent varies across all consumers:

  • 36% prefer text
  • 32% prefer email
  • 4% prefer a paper letter mailed
  • 1% prefer receiving a phone call

But for most businesses, executing an advanced outreach strategy can be a major undertaking, especially for those used to relying on traditional call-and-collect methods. Partnering with TrueAccord can alleviate the potential strain on resources and simultaneously help you collect more faster.

TrueAccord not only engages your delinquent customers through this proven effective omnichannel approach, but also leverages our patented machine learning engine, HeartBeat, to effectively ​​reach out to every account placed with a goal of getting them to repay on their own terms when they are ready. HeartBeat dynamically optimizes the next best touchpoint for every consumer in real-time, including the content, timing, and channel for each customer.

No matter where your customers fall in the consumer spending divide, TrueAccord has the right message, right channel, and right timing to recover more across the board.

Ready to get started? Schedule a consultation today»»

Sources:

Q2 Industry Insights: Beating the Economic Heat and Keeping Up with Compliance

By on July 9th, 2024 in Industry Insights

The dog days of summer are ahead, and with inflation and high interest rates still sticking around, consumers in the U.S. will be feeling the heat financially. Consumer sentiment and data-based indicators tell some of the story, but what better way to gauge the consumer financial landscape than by looking at how people spend their free time and money? 

While consumers embraced the ‘YOLO economy’ coming out of pandemic times – spending wildly on products and experiences – today’s high inflation, low savings and a cooling job market have shifted priorities for many, leading to weakened consumer spending. And businesses are responding accordingly to the lower demand – several top musical acts from Jennifer Lopez to the Black Keys have canceled summer tours due to low ticket sales while retailers like Walmart and Target are lowering prices on certain goods to appeal to budget-strained shoppers. 

Despite families looking for ways to save this summer, their vacation plans must go on. The Transportation Security Authority has been anticipating and reporting record air travel numbers while a recent LendingTree survey found that 45% of parents go into debt to pay for a Disney vacation and few have regrets about it, indicating people will still prioritize spending for some experiences.

Meanwhile, the Consumer Financial Protection Bureau (CFPB) has been busy, with new rules impacting lenders and collectors across the spectrum. What does this all mean and what’s the outlook for the second half of the year? Read on for our take on what’s impacting consumer finances, how consumers are reacting and what else you should be considering as it relates to debt collection in 2024.

What’s Impacting Consumers?

Inflation finally started slowing in May and then showed a decline in June, landing at 3% from a year ago and the lowest level in more than three years. Both headline and core inflation beat forecasts but housing costs continued to rise and remain a key contributor to inflation. Being heavily weighted in the Consumer Price Index (CPI) formula, it’s unlikely to see big drops in CPI until these costs start to fall. In June, Federal Reserve officials held the key rate steady and penciled in a single rate cut this year while forecasting four in 2025, reinforcing calls to keep borrowing costs higher for longer. Meanwhile, the labor market has moved close to its pre-pandemic state and the overall economy continues to grow at a solid pace.

But even the 2% drop in the energy index won’t be enough to combat the inflated cost of keeping cool this summer, with predicted extreme heat set to drive home cooling costs up to a 10-year high. The average cost of keeping a home cool from June through September is set to reach $719, nearly 8% higher than last year and a big jump from the 2021 average of $573. Concerningly for lower-income households, organizations distributing federal financial support expect they’ll be able to help roughly one million fewer families pay their energy bills this year, in part due to government funding for the Low Income Home Energy Assistance Program (LIHEAP) falling by $2 billion from last fiscal year.

Coming out of Q1, total household debt rose by $184 billion to reach $17.69 trillion, according to the Federal Reserve Bank of New York’s latest Quarterly Report on Household Debt and Credit. Mortgage and auto loan balances continued climbing, increasing to $12.44 trillion and $1.62 trillion respectively. Overall, delinquency indicators decreased positively as we moved through Q2 as seasonally expected, partly due to tax season. In May, overall delinquent balances (30+ DPD) increased by 3.46%, driven by a 6.06% increase in delinquent mortgage balances. But mortgage was an exception, not the norm: there was a 0.55% decrease MoM in 30+ DPD delinquent accounts overall. 

Credit card balances also declined seasonally as expected in Q1 to $1.12 trillion, but new delinquencies rose with nearly 9% of credit card balances and 8% of auto loans transitioning into delinquency. Despite this latest decrease, credit card balances are still up $259 billion since the fourth quarter of 2021. Thanks to record interest rates, stubborn inflation and other economic factors, credit card balances are likely only going to climb, despite what we saw in the first half of the year.

The verdict is still out on how those with student loans are faring with resumed payments. Missed federal student loan payments will not be reported to credit bureaus until the fourth quarter of 2024. Because of these policies, less than 1% of aggregate student debt was reported 90+ days delinquent or in default in the first half of the year and will remain low through the end of the year.

Busy Season at the CFPB

With a flurry of announcements in the past few months, the CFPB has been busy. The biggest win: a long-awaited United States Supreme Court decision came out in May ruling that the CFPB’s funding is constitutional, leaving the Bureau free to uphold its mission of protecting consumers and ensuring that all Americans are treated fairly by banks, lenders and other financial institutions.

On the consumer fairness front, and after releasing research showing that 15 million Americans still have medical bills on their credit reports despite changes by Equifax, Experian and TransUnion, the CFPB proposed a rule to ban medical bills from credit reports, a move that would remove as much as $49 billion of medical debts that unjustly lower consumer credit scores. In another attempt to help consumers by bringing homeownership back into reach amidst high interest rates and home prices, the CFPB also started an inquiry into mortgage junk fees and excessive closing costs that can drain down payments and push up monthly mortgage costs.

As related to business operations oversight, in June the CFPB issued a new circular on “unlawful and unenforceable contract terms and conditions in contracts for consumer financial products or services.” This warning makes it clear that it is a UDAAP (Unfair, Deceptive, or Abusive Acts or Practice) to have an unlawful, unenforceable term in contracts with consumers.

Later in June, the CFPB also finalized a new rule to establish a registry to detect and deter corporate offenders that have broken consumer laws and are subject to federal, state or local government or court orders. This registry will help the CFPB to identify repeat offenders and recidivism trends to hold businesses accountable as historically, nonbank entities faced inconsistent oversight, making it challenging for regulators to identify and address potential risks to consumers.

As the CFPB works to accelerate the shift to open banking in the United States, it also announced a new rule establishing a process for recognizing data sharing standards and preventing dominant incumbents from inhibiting startups.

At the end of June, the Supreme Court overturned the Chevron doctrine, a precedent that has allowed federal agencies like the CFPB significant authority to interpret ambiguous laws. This means that judges will use their own judgment to interpret laws rather than deferring to agency interpretations, making it easier to challenge and overturn agency regulations. As a result, the industry’s regulatory framework will become more unpredictable as courts take a larger role in interpreting laws and will require businesses to monitor and adapt their compliance and legal strategies.

A Roller Coaster of Consumer Sentiment

The first half of 2024 has been an economic roller coaster for consumer spending, resulting in whiplash for consumer sentiment. While the soft landing may still be on track, that track doesn’t appear to be as straightforward as hoped. There is an onslaught of mixed messages from, “consumers are proving to be more resilient than expected as they continue to spend, staving off what had been predicted to be an inevitable recession” to “consumers are actually financially stretched from depleting their pandemic-era savings and battling ongoing inflation and higher interest rates”.

The latest Paycheck-to-Paycheck report from PYMNTS Intelligence found that as of March, 58% of all U.S. consumers live paycheck to paycheck, regardless of their income levels. Causes for this financial situation vary and range from insufficient income and family dependents to large debt balances and splurging unnecessarily. While financial goals also vary across consumer segments, paying down debt is one common goal across all generations: 15% of Gen Z, 20% of millennials, 23% of Gen X and 22% of baby boomers and seniors said repaying debt is a priority.

Recent consumer surveys have found that 22% of respondents expressed feeling less discomfort about spending a lot of money when using a credit card, and more than half reported they are more likely to make impulse purchases when using cards. Whatever the sentiment, people are feeling some confidence to continue to spend and continue to carry a debt balance, with 41% of consumers reporting a revolving month-to-month balance on their credit cards.

What Does This Mean for Debt Collection?

Between these highs and lows of economic indicators and consumer sentiment, a serious fact remains for businesses: delinquency will continue to be an issue through 2024. For companies looking to recover those delinquent funds, understanding how to communicate with consumers where they are in this roller coaster can mean the difference between repayment and write-off. For lenders and collectors, here are some things to consider:

  1. Shift the collection mindset. Pivoting debt resolution operations from only being focused on roll rates and placements to a more consumer-centric engagement strategy is the first critical step to productively engaging consumers.
  1. Customization is key. Effective debt recovery communications will resonate with consumers and match where individuals are with the right message to engage with empathy and options for repayment; the right channel to engage through their preferred method of communication; and the right time to engage on their own terms when they are ready.
  1. Don’t skimp on compliance. Not only does following the rules of debt collection keep you out of hot water, adhering to the consumer-friendly rules will set up the best possible experience for consumers, leading to better engagement and repayment rates. Here’s a comprehensive look at what you need to know about collections compliance to get started.

SOURCES:

A Busy Summer for the CFPB—And Consumers Will Benefit in the Long Run

By on June 20th, 2024 in Industry Insights

It’s already been a busy summer for the Consumer Financial Protection Bureau (CFPB)—Supreme Court rulings, fine print warnings, new registries, and more—all in the continued effort to better protect consumers’ financial health and wellbeing. 

Before we dive into the latest CFPB news, let’s have a refresher on what this bureau is and why it is so important:

The Consumer Financial Protection Bureau, or CFPB, was formed in the wake of the 2008 financial crisis, under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, with a mission to implement and enforce federal consumer financial law by holding companies accountable from industries such as payday loans, credit cards, student loans and mortgages.

With this mission in mind, let’s take a closer look at the CFPB news round-up so far this summer and understand its impact for consumers, businesses, and the economic landscape.

Supreme Court Rules and “the CFPB is Here to Stay”

The long awaited United States Supreme Court decision on the CFPB came out May 16, 2024: the CFPB is constitutional.

This constitutionality case was brought by representative groups of the payday loan industry, the Community Financial Services Association of America and the Consumer Service Alliance of Texas, alleging that the CFPB’s funding mechanism is unconstitutional under the Appropriations Clause.

Pundits expected a different outcome from this conservative majority court. In a 7-2 decision, one of the most conservative, Justice Thomas, wrote the majority opinion for an alignment of liberal and conservative Justices (Thomas, Roberts, Sotomayor, Kagan, Kavanaugh, Barrett, and Jackson), stating that the CFPB’s funding mechanism is constitutional since the Bureau draws its budget through the Federal Reserve, rather than an annual appropriation by Congress.

Since the CFPB operates as a consumer watchdog agency funded by the Federal Reserve System, not Congress, the Bureau’s funding mechanism is meant to safeguard the agency’s funding against changes in the political climate, unlike most other federal agencies. Instead, it obtains its funds by making a request to the Federal Reserve, which may not exceed 12% of the Federal Reserve’s “total operating expenses.”

Upon receiving the news, the CFPB issued a statement: “The Court repudiated the arguments of the payday loan lobby and made it clear that the CFPB is here to stay.”

The Fine Print: CFPB Warns About Financial Services Contract Terms

Then on June 4, 2024, fresh off the Supreme Court victory, the CFPB issued a new circular on “unlawful and unenforceable contract terms and conditions in contracts for consumer financial products or services.” 

This latest warning now makes it clear that it is a UDAAP (Unfair, Deceptive, or Abusive Acts or Practice) to have an unlawful, unenforceable term in contracts with consumers. These types of consumer contracts can also be perceived as an attempt to confuse people about their rights—such as the general liability waiver, which claims to fully insulate companies from suits even though most states have enacted legal exemptions to these waivers. 

When financial institutions enact this fine print tactic to try to trick consumers into believing they have given up certain legal rights or protections, they now risk violating the Consumer Financial Protection Act.

“Federal and state laws ban a host of coercive contract clauses that censor and restrict individual freedoms and rights,” said CFPB Director Rohit Chopra. “The CFPB will take action against companies and individuals that deceptively slip these terms into their fine print.”

This latest warning is part of the CFPB’s broader efforts to “ensure freedom and fairness in people’s interactions with financial institutions.”

CFPB Creates Corporate Offender Registry 

In this continued effort, CFPB also finalized a new rule in June to establish a registry to detect and deter corporate offenders that have broken consumer laws and are subject to federal, state, or local government or court orders. 

Initially proposed in December 2022, the registry will also help the CFPB to identify repeat offenders and recidivism trends. Historically, nonbank entities faced inconsistent oversight, making it challenging for regulators to identify and address potential risks to consumers. The registry will help the CFPB and other law enforcement agencies monitor and track repeat offenders in order to better hold them accountable if they break the law again.

“Too many American families have been harmed by corporate repeat offenders in a rinse-and-repeat cycle of illegality, where bad actors see fines and penalties as the cost of doing business,” recounts CFPB Director Chopra. 

Larger non-bank participants will be among the first block of registrations due January 14, 2025, with other companies under the umbrella having until April 14, 2025, followed by July 14, 2025 to register if they have been caught violating consumer law previously. 

A Bureau news release on June 3, 2024 emphasized that “reining in repeat offenders is a priority for the CFPB,” as they introduced not only the new rule and registry, but also the establishment of the new Repeat Offenders Unit.

“In the United States, it is common practice to establish registries of offenders to protect the public and to help prevent repeat offenses,” explains Director Chopra. “The CFPB’s registry will enable the agency to more effectively monitor the marketplace for companies that pose particular risk to consumers.”

Upholding Its Designation as the “Consumer Watchdog” 

All of these announcements and actions over the last few weeks prove that the CFPB is still upholding the Bureau’s mission of protecting consumers and ensuring that all Americans are treated fairly by banks, lenders, and other financial institutions. Its reputation as the “Consumer Watchdog” continues to be well-earned as the economic landscape evolves. 

Sources:

The Roller Coaster of Consumer Spending, the Whiplash of Consumer Sentiment, and How to Effectively Engage for Collections

By on June 5th, 2024 in Customer Experience, Industry Insights, User Experience

At the end of 2023, economists were hoping for a “boring” 2024—just a relatively uneventful year thanks to a soft landing with downward trends for inflation, unemployment, and interest rates.

But instead, the first half of 2024 has been an economic roller coaster for consumer spending, resulting in a whiplash for consumer sentiment. While the soft landing may still be on track, that track doesn’t appear to be as straightforward as hoped. There is an onslaught of mixed messages:

Consumers are proving to be more resilient than expected as they continue to spend, staving off what had been predicted to be an inevitable recession

versus

Consumers are actually financially stretched from depleting their pandemic-era savings and battling ongoing inflation and higher interest rates

And between these highs and lows, a serious fact remains for businesses: delinquency transition rates have increased across all debt types. But for companies looking to recover those delinquent funds, understanding how to communicate with consumers where they are in this roller coaster can mean the difference between repayment and write-off.    

Let’s look at the recent trends between consumer spending and consumer sentiment and how businesses can effectively engage with customers in the event of delinquency.

Roller Coaster of Consumer Spending

Up and down the economic roller coaster goes, but the ride may be feeling different for different subsets of consumers: Americans with higher incomes have continued to spend at healthy rates, yet lower- and middle-income consumers are starting to pull back.

This “split-spending” pattern hasn’t been the case in recent years—pandemic-era benefits, a savings surplus, and rapid wage growth resulted in consistent spending rates across all income groups. But as excess pandemic savings decline at the same time as both inflation and interest rates increase, lower-income consumers are feeling the squeeze while higher-income consumers are mostly unaffected.

And even when there is a spending uptick in the lower-income sector, like we saw in April 2024, what these consumers are spending on and how they are paying for it is still quite different from their higher-income counterparts. These spending patterns show that consumers are “trading down,” or changing the type or quantity of purchases for better pricing and value, and are starting to put more everyday bills on credit cards—and in turn, credit card delinquencies and charge-offs for low-income consumers are returning to their pre-pandemic levels faster than other groups.

Regardless of where on the financial spectrum individuals may fall, an overall slowdown is expected. According to a Fitch Ratings report, annual consumer spending growth will lower from 2.2% in 2023 to 1.9% in 2024, with much of the slowdown expected in the second half of the year as income growth decelerates, pandemic savings dissipate, and higher interest rates persist.

And the Whiplash of Consumer Sentiment

So how is this roller coaster affecting how consumers feel about the economy and their own financial outlook? Overall, consumers are reporting they plan to spend less money on discretionary items in the coming months, with approximately 40% citing affordability constraints due to “economic reasons,” but that doesn’t quite capture the true whiplash of consumer sentiment we are seeing month over month:

  • January: Consumer surveys find that 43% of respondents describe the economy as very good—but 59% are also worried about inflation.
  • February: The Consumer Sentiment Index fell in the February 2024 survey, down from the more positive outlook reported in January.
  • March: U.S. consumer sentiment rose unexpectedly in March to reach the highest it’s been in nearly three years.
  • April: Consumer confidence deteriorates and falls to its lowest level in more than a year and a half.
  • May: The Consumer Sentiment Index reports the largest decline in the index in approximately three years amid worsening concerns around inflation.

Despite these swings, recent consumer surveys have found that 22% of respondents expressed feeling less discomfort about spending a lot of money when using a credit card, and more than half reported they are more likely to make impulse purchases when using cards. Whatever the sentiment, people are feeling some confidence to continue to spend and continue to carry a debt balance, with 41% of consumers reporting a revolving month-to-month balance on their credit cards.

Looking at the dramatic spikes and dips in sentiment makes knowing how to message and engage delinquent consumers critical to eliciting commitments for repayment—especially when we already noted above that delinquencies and charge-offs are returning to pre-pandemic levels for certain income sectors.

How to Handle the Roller Coaster and Whiplash and Effectively Engage With Delinquent Consumers

So we’ve seen how although the roller coaster of spending trends may actually be split into two different tracks between income levels, consumers across the board are experiencing an almost monthly back-and-forth whiplash in their financial outlook and sentiment—how are debt collection and engagement strategies supposed to keep up when consumers are on this wild ride? In today’s world, traditional methods of outbound calling and mass blast emails are the epitome of “spray and pray” chasing the tail of the roller coaster and rarely reaching one of the consumers holding on.

To engage with today’s consumers, customization is key. Your debt recovery communications need to match where individual consumers are with the:

  • Right message – engage with empathy and options for repayment
  • Right channel – engage through their preferred method of communication
  • Right time – engage compliantly when they are ready

This means most businesses need to shift the mindset of debt resolution operations from only being focused on roll rates and placements to a more consumer-centric engagement strategy. Yet many collection agencies still practice call-and-collect (and struggle due to declining right-party-contact rates and tightening regulations), and even those using email will typically only develop basic messaging for all customer communications.

Effective debt recovery needs to take consumers’ roller coaster into account—but how?

TrueAccord’s patented machine learning engine, HeartBeat, ​​reaches out to every account placed with a goal of getting them to repay on their own terms when they are ready, versus the one-size-fits all communication that ignores trends in sentiment and spending habits.  

Powered by a combination of data-driven heuristics, the latest compliance regulations, and machine learning—continuously refined by data from our 20 million customer engagements and counting—HeartBeat dynamically optimizes the next best touchpoint for every consumer in real-time, including the content, timing, and channel for each customer. It leverages interaction signals to identify consumers at risk of breaking plans and automatically adapts to keep them successful until resolution.

The TrueAccord approach aims to engage and empower no matter where the roller coaster may be taking individual consumers. As we continue to listen, learn, and innovate, we remain committed to delivering exceptional debt collection experiences that prioritize consumer well-being paired equally with debt recovery.

What Do Consumers Have to Say About TrueAccord’s Engagement Approach?

“I really have enjoyed TrueAccord because they give you so many options that align with your finances, work schedule and once you commit to a schedule they still allow you more time to pay if something comes up. Everything is customizable to you which makes it so much easier to pay down your debts, never harder. They make it very user friendly and straightforward. I really appreciate this company and what they do for you.”

“Absolutely amazing! I really get uncomfortable admitting I need help, and calling and settling a debt. This being done by email initially made the process less stressful and myself less anxious about the whole thing. Much appreciated! Would recommend using TrueAccord to anyone that has the opportunity to settle a debt. Thank you so much.”

“I just want to commend True Accord for their professionalism as well as their empathy and outstanding customer service. NEVER have I encountered a collection company with such superb service, they did not continually harass me nor did they ever make threats in order to obtain payment, they understood my situation, and worked 110% to accommodate a payment plan specific to my financial situation.”

“I really appreciate the patience and kindness I feel I get with this company. Makes it easier to pay my bills.”

“I have dealt with enough “collectors” to be able to honestly say your company, Trueaccord, was the easiest to deal with. Allowing me to set up my own plan, not calling 15 times a day. You made this as easy as possible and without the stress! Thank you for such a stressless collection procedure.”

“I have been very backed up on getting my finances in order. I love how emails would always pop up and remind me. Finally got this one off my bucket list!”

“It was a joy working with you all, making it an easy experience. Thank you for making the ride a smooth one, slowly cleaning up our debts thanks to your company.”

Ready to get started? Schedule a consultation today»»

Sources:

Digital-First Debt Collection Delivers 35% Liquidation Increase for Leading Telecoms

By on May 1st, 2024 in Customer Experience, Data Report, Industry Insights, Product and Technology, User Experience

Telecom Industry Evolves, But Call-and-Collect Can’t Keep Up

The telecommunications industry has evolved hand-in-hand with most consumer communication preferences throughout the decades. From the last remaining landlines to mobile and internet services, it’s challenging to find a consumer that doesn’t subscribe to a Telecom service.

Yet while Telecoms enable customers to communicate and access products and services via digital channels wherever they go, the industry’s own methodology for communicating with consumers who have fallen delinquent on their bills is quite antiquated for the modern world they operate in.

Many Telecoms have traditionally used call centers for collection services to collect charged-off debt, but face mounting challenges all contributing to less revenue:

These challenges are not unique to telecoms, but considering the evolution of the industry it would only make sense that their debt collection practices would also adapt to consumer preference for digital and omnichannel communications.

Future-Facing Digital-First Solutions Deliver Real Liquidation Results

For some of the leading Telecom providers in the US, the time had come to face the declining third-party liquidation performance and reevaluate their debt recovery approach. A more future-forward, effective engagement model was being adopted throughout other industries and it was time for these Telecoms to test the waters of digital-first outreach for late stage collections…and TrueAccord was there to be their guide.

Through a champion-challenger model during the six-month pilot, TrueAccord’s digital-first, omnichannel engagement proved to be more effective at recovering from the late stage accounts. Between multiple portfolios across three Telecom providers, the results tipped the scale so moving forward all accounts would be serviced entirely through TrueAccord’s platform.

Each of the Telecom providers saw notable increases in liquidation using TrueAccord compared to their traditional call-and-collect methods:

  • First Telecom: 35% increase
  • Second Telecom: 7% increase
  • Third Telecom: 32% increase

How did TrueAccord’s digital-first approach deliver these kinds of results? Get the detailed breakdown in our in-depth Telecom case study»»

Are you ready to evaluate your legacy collections servicer against TrueAccord’s proven digital-first, omnichannel approach? Schedule a consultation today!

Q1 Industry Insights: Persistent Inflation is Bananas and a Tale of Two Consumers

By on April 15th, 2024 in Industry Insights

Way back in January, 2024 was looking strong with decreasing inflation holding the promise of interest rate cuts that would ease the strain on consumer finances and reopen a tight market. Three months into the year, the outlook isn’t looking quite as rosy, but optimism for change persists. While the looming threat of a recession has passed, the outlook seems to point to inflation sticking around and consumer sentiment on the financial outlook this year is mixed. Case in point – even Trader Joe’s gave in and raised the price of bananas, from 19 to 23 cents, for the first time in 20 years, with loyal shoppers calling the move “the end of an era”. The Federal Reserve is still poised for a couple of rate drops this year, though the timing and impact of those are more in question, especially with the resilient labor market that could push interest rate cuts to later in the year to ensure inflation is truly tamed before acting and the global conflicts that are impacting Wall Street and interest rates.

The first quarter of the year coincides with tax season, when many consumers realize a tax refund that helps the strain on finances, which in turn produces an uptick in debt repayment. Strong liquidation rates this quarter don’t necessarily signal how the following months will perform. How has the economy impacted consumers this quarter and what’s in store for the rest of the year? Read on for our take on what’s impacting consumer finances, how consumers are reacting, and what else you should be considering as it relates to debt collection in 2024.

What’s Impacting Consumers?

Inflation persisted in Q1. The Labor Department’s Bureau of Labor Statistics reported that CPI rose 0.4% in March, bringing the 12-month inflation rate to 3.5%, or 0.3% higher than in February. This increase was driven by shelter and energy costs, with energy rising 1.1% after climbing 2.3% in February, while shelter costs increased by 0.4%, up 5.7% from a year ago. The Fed has been expecting shelter-related costs to decelerate through the year, which would allow for interest rate cuts, so this rising indicator is not favorable for consumer economic outlook.

Consumers kicked the year off with debt trending higher. According to the Federal Reserve Bank of New York’s latest Quarterly Report on Household Debt and Credit, total household debt rose by $212 billion to reach $17.5 trillion in Q4 of 2023 and credit card balances increased by $50 billion to a record $1.13 trillion. Mortgage and auto loan balances also rose, with the Bank saying the data indicates financial distress is on the rise, particularly among younger and lower-income Americans.

The emerging situation is what recent reports have dubbed “a tale of two consumers”. One consumer cohort is the roughly two-thirds of Americans who have done substantially well, own their homes and/or have invested in the stock market – this group had the savings cushion necessary to weather high inflation. The other cohort, made up of mostly middle- and lower-income renters who have not benefited from the wealth effect of higher housing and stock prices, has been hit harder by inflation and is feeling more financial stress.

Experts worry that members of this second cohort are falling behind on their debts and could face further deterioration of their financial health in the year ahead, particularly those who have recently resumed paying off student loans. While approximately 4 million relieved Americans have benefitted from $146 billion in student debt relief as a result of the Biden-Harris Administrations myriad executive actions, millions more are still left trying to add resumed payments back into their budgets amidst a stubbornly high cost of living.

To cover this additional monthly debt, 33% of surveyed consumers with student loans planned to reduce discretionary spending or use their savings; 28% said they would get a second job or do part-time or temporary work; 25% will use money from retirement savings; 21% will use credit card available limits; and 19% will borrow from family or friends, or delay a key milestone like marriage or home purchase. For those who expect student loan forgiveness, 57% surveyed say they would use savings from forgiveness to pay off debt, 10% would put the savings toward a home purchase, 26% say they would put savings toward other savings and 7% say they would spend their savings on other things, according to the Federal Reserve’s latest Survey of Household Economics and Decisionmaking.

A Growing Mountain of Credit Card Debt and Other Indicators

For consumers who turn to credit cards to make ends meet, higher interest rates are making it more costly to carry a balance on a credit card, with the average credit card APR at a record 24.66%. Debt holders are also carrying their debt for longer periods of time, and struggle to pay it off as it compounds. According to a LendingTree analysis of more than 350,000 credit reports, the average unpaid credit card balance was $6,864 in Q4 2023. 

This starts showing up in increased credit card delinquencies, which soared more than 50% by the end of 2023, with about 6.4% of all accounts 90 days past due, up from 4% at the end of 2022. Delinquency transition rates also increased for almost all other debt types, with the exception of student loans. According to Experian’s Ascend Market Insights, overall 30+ days past due delinquency grew, starting the year with a 2.31% increase in delinquent accounts and 10.49% increase in delinquent balances month over month. Q1 of 2024 is also showing a rise in early-stage delinquencies, ticking up from 0.98% in January to 1.04% in February.

Missing payments correlate to another indicator of consumer financial health – the U.S. personal saving rate dipped down to 3.6% in February, compared to 4.1% in January and 4.7% in 2023. The situation remains that a majority of U.S. consumers (59%) live paycheck to paycheck as of February 2024, including 42% of those earning more than $100,000 per year. As an alternative to taking on debt, many Americans are taking on side jobs to increase income instead – as of February 2024, 22% of workers had a side job. The data also shows that 30% of employed consumers earning supplemental income depend on this money to make ends meet, up from 25% last year.

Consumers Worried About Inflation and Debt Accumulation

Unsurprisingly, 82% of consumers surveyed say concerns about inflation top their lists of economic woes, with only 17% holding out any hope that inflation will subside anytime soon. One of the few solutions available to consumers hoping to fight back against inflation is an increase in their paycheck, but the report found that fewer than 4 in 10 consumers anticipated a wage increase this year, down from 43% who expected a raise last year. According to the latest Compensation Best Practices Report, 79% of organizations are planning to give pay increases in 2024—the lowest number in years—in light of a strong labor market and cooling inflation, down from 86% in 2023. And the amount of raises planned for this year are generally smaller, with organizations predicting an average base pay increase of 4.5%, compared to the average of 4.8% given in 2023.

A slim majority of Americans (56%) reported optimism about their household finances in the next 12 months, according to TransUnion’s Consumer Pulse Survey from Q4 2023. Millennials had the highest optimism among generations (71%) while Baby Boomers had the lowest (44%). Millennial optimism likely spurred from reported income increases and expected higher income growth in the next 12 months.

The Conference Board reported a mixed bag of consumer sentiment, with assessments of the present situation improving in March, primarily driven by more positive views of the current employment situation, while expectations for the next six months deteriorated. PYMNTS Intelligence data found that 15% of consumers say debt accumulation was a main pressure point on their savings, having dipped into those accounts to ease their debt burdens. 

What Does This Mean for Debt Collection?

With a mixed and uncertain economic outlook, consumers will be watching their finances closely. While some populations may reap wealth effect benefits and fare well financially, others will face headwinds with sticky high prices and student loan payments. For debt collectors, it will be critical to provide the right experience for each consumer and understand that everyone has a different financial situation with different considerations. While the first quarter may have brought increased liquidation due to cash influxes from tax season, the following months may bring challenges. We’ll soon find out, but as a lender or collector, here are some things to consider:

  1. Personalize your messages. What works for one consumer won’t necessarily work for the next. Consider the customer journey and tailor messaging so it resonates with consumers at different points in the debt collection process. It’s not just what you say, but how and when you say it that will determine how consumers respond. Learn more about the stages of the debt resolution funnel.
  1. Give options. For consumers balancing tight finances, paying a lump sum may not be possible. Payment plans facilitate smaller payments over time that consumers can work into their budgets. Other options like choosing what day to pay and the ability to reschedule a payment will also help consumers stay on track to repayment.
  1. Make it easy. When paying back debt is as simple as click→review→pay online, consumers will be more likely to engage. Using digital channels and giving consumers the pertinent information upfront so they can engage when and how they prefer means cutting out the middleman and empowering consumers to self-serve. 96% of consumers working with TrueAccord resolve their accounts without speaking to a human and often at times outside of standard customer service hours.