Category: Industry Insights

Data Protection is Critical in Debt Collection: GLBA, Consumer Trust, and Best Practices to Protect Your Business

By on June 29th, 2023 in Compliance, Industry Insights

In today’s financial landscape, regulators at both the federal and state level are driving accountability for companies when it comes to data protection and security. We see that with the express requirement in the Gramm-Leach-Bliley Act, or GLBA, Safeguards Rule—which went into effect on June 9, 2023—that organizations have one qualified individual to oversee the information security program, and that the qualified individual provides regular reports to the highest governing body of an organization.
This underscores the importance of protecting customer information in a digital age where information has its own intrinsic value.

Let’s take a look at how the new updates to GLBA Safeguards Rule, how these security policies are important specifically for debt collection, and what best practices your business should follow to protect consumers’ data.

 The GLBA Data Protection Law

The Gramm-Leach-Bliley Act, or GLBA, is a federal regulation to control how financial institutions collect, store, and transmit consumer information. GLBA was enacted by the Federal Trade Commission (FTC) in 1999 and recently rolled out new amendments to the Standards for Safeguarding Customer Information, known as the “Safeguards Rule,” that went into effect on June 9, 2023, in effort to continue protecting consumer data in an ever-evolving digital environment. 

A few of the updates to GLBA’s Safeguards Rule include:

  • Provides covered financial institutions with more guidance on how to develop and implement specific aspects of an overall information security program
  • Improves the accountability of these security programs, such as requiring financial institutions to designate a qualified individual responsible for overseeing, implementing and enforcing the program

Data Protection is Critical in Debt Collection

To attract clients today a debt collector must demonstrate the implementation of a full suite of information security practices covering physical, technical, and administrative safeguards, including a comprehensive employee information security training. Failure to implement these best practices can result in a security incident or worse, a data breach. Not only are data breaches costly because of the notification provisions, including providing credit bureau monitoring, it can be difficult for a company to survive after a breach. It is not unusual for a company to file bankruptcy after a data breach.

Reputation and Customer Retention

Although complying with federal and state regulations helps companies avoid costly—even criminal—penalties, consumer trust that their financial data is being protected is critical to maintaining a positive reputation and retaining customers (even if they fall into delinquency).

Data protection policies can often be treated as a set-it-and-forget-it, or even treated as a luxury of lower priority due to limited resources, expertise, or familiarity. But for today’s consumers, data security is a top priority.

A recent study by MAGNA Media Trials and Ketch, showed across every age group74% of people rank data privacy as one of their top values—consistently rank data privacy as their top concern. And on the flip-side, the study showed nearly 9 out of 10 consumers report strong data privacy practices positively impact their relationship with a company.

Keeping Up With Compliance

Along with federal regulations, individual states are also issuing new laws focused on consumer data protection. California, Utah, Colorado, Connecticut and Virginia all passed data privacy laws over the past several years that take effect in 2023. This past March, Iowa passed a Data Privacy Law that takes effect on January 1, 2025 that is very similar to both Virginia and Colorado’s laws affording consumers a right to know and right to request deletion. Pennsylvania amended its Breach of Personal Information Notification Act, by among other things, expanding the definition of “personal information” to include medical and health information, and a username or e-mail address in combination login credentials. Several more states have draft privacy and security laws in draft.

Although GLBA and other data protection and privacy laws are the hot topic when it comes to compliance today, it isn’t the only federal privacy regulations lenders and debt collectors need to follow and monitor for changes—or face the consequences of non-compliance. Here are some recent laws and amendments impacting the industry:

  • The Fair Credit Reporting Act: Credit reporting companies and users of credit reports have specific obligations to protect the public’s data privacy, with potential criminal liability for certain misconduct.
  • The Dodd-Frank Wall Street Reform and Consumer Protection Act: Established a new Consumer Financial Protection Bureau with the authority to supervise and regulate entities that offer or provide consumer financial products or services.
  • Health Insurance Portability and Accountability Act (HIPAA): Two part rule for privacy and security of personal health information that applies to covered entities (doctors, hospitals, pharmacies, insurers, and their vendors). PHI – is defined broadly to include any information provided to the covered entity by the patient.

Consumer Data Protection is Not a Luxury

Having good security practices in place is not only beneficial for both consumers and businesses, but also critical to stay compliant with all the new laws and amendments being introduced. Here are some of the best privacy and security practices to implement to protect customers, companies, and stay compliant:

  • Practice data minimization.
  • Know where personal information lives at all times by creating a data map of where the data goes and is stored throughout your systems, which includes knowing your vendor’s data security and privacy practices and controls.
  • Know who has access to personal information and routinely examine if that access is necessary to complete that job function.
  • Be intentional with how data is organized and stored so it can be easily segmented and treated differently if need be (think network segmentation).
  • Have a public facing Privacy Notice–and make sure it accurately reflects your practices for use, collection, deletion and correction.
  • Conduct an annual data security risk assessment to continually reassess areas for improvement and where you may need additional controls.
  • Ensure contracts with parties whom you receive and/or give personal information to specifically address each parties’ obligations and restrictions for how personal information is used, shared, disclosed, stored, and sold (if permitted).

The TrueAccord Approach

At TrueAccord, empathy towards the consumer is a core part of our company mission: we enable businesses to collect more, faster, and from happier customers.

Ready to collect more, faster from happier customers? Learn how TrueAccord weaves compliance and data security into debt recovery by scheduling a consultation today»»

A Closer Look at the Gramm-Leach-Bliley Act (GLBA): Updates to the Safeguards Rule

By on June 6th, 2023 in Compliance, Industry Insights

Protecting personal and financial information is critical in today’s digital age. Where data has its own intrinsic value and where data breaches and cyberattacks are a risk for every business, the Safeguards Rule under the Gramm-Leach-Bliley Act (GLBA) provides financial institutions, including those in the accounts receivable management industry, with guidance on how to safeguard customer information.

The existing Safeguards Rule provided financial institutions with much flexibility and discretion when determining what kinds of safeguards were best for their organizations and risks. With the amendments which go into effect on June 9, 2023 financial institutions now have a more prescriptive recipe for what those safeguards need to be.

What is the Gramm-Leach-Bliley Act (GLBA)?

The Gramm-Leach-Bliley Act, or GLBA, is a federal regulation to control how financial institutions collect, store, and transmit consumer information. Although GLBA was enacted by the Federal Trade Commission (FTC) in 1999, changes have been anticipated for the last few years.

In October 2021, the FTC announced new amendments coming to the Standards for Safeguarding Customer Information, known as the “Safeguards Rule,” and an issuance of a final rule, referred to simply as the “Final Rule.” Originally set to go into effect in 2022, financial institutions—a designation that has also been updated—now need to prepare for the changes or risk non-compliance and its consequences before they go into effect on June 9, 2023.

What is the Safeguards Rule?

The Safeguards Rule took effect January 10, 2021, and its requirements were first set to go into effect beginning December 9, 2022, but the FTC announced it would extend the deadline for financial institutions to develop, implement, and maintain a comprehensive information security program by June 9, 2023.

There are five overarching modifications to the existing Safeguards Rule:

  • Provides covered financial institutions with more guidance on how to develop and implement specific aspects of an overall information security program
  • Improves the accountability of these security programs, such as requiring financial institutions to designate a qualified individual responsible for overseeing, implementing and enforcing the program
  • Exempts financial institutions that collect information on fewer than 5,000 consumers from the requirements of a written risk assessment, incident response plan, and annual reporting to the board of directors
  • Expands the definition of “financial institution” within the scope of the Safeguards Rule – see the expanded definition in the next section below
  • Includes several other definitions and related examples in the amended Safeguards Rule itself in an effort to make it more self-contained and to enable readers to understand its requirements without referencing the FTC’s Privacy of Consumer Financial Information Rule

Along with these updates to the Safeguards Rule, let’s examine a few other specifications of the updates.

What are other updates to the Safeguards Rule?

The expanded scope of financial institutions that are subject to the Safeguards Rule is significant. Under the new Final Rule, “financial institutions” now include entities engaged in activities that the Federal Reserve Board determines to be incidental to financial activities, such as:

It is important to note that the Final Rule does not apply to national banks, savings and loan institutions, and federal credit unions, as these institutions are not subject to the FTC’s jurisdiction.

The Final Rule requires these covered financial institutions to comply with specific new requirements, such as:

  • Encrypt all customer information held or transmitted in transit over external networks and at rest
  • Multi-factor authentication for any individual accessing any information system, unless the use of reasonably equivalent or more secure access controls has been approved in writing by a qualified individual at the financial institution
  • Conduct periodic written risk assessments, and the results of such risk assessments should drive the information security program
  • Create procedures for evaluating, assessing or testing the security of externally developed applications used to transmit, access or store customer information
  • Set procedures for secure disposal of customer information no later than two years after the last date the information is used
  • Implement policies, procedures, and controls designed to monitor and log the activity of authorized users and detect unauthorized access or use of, or tampering with, customer information by such users
  • Provide personnel with security awareness training, and provide information security personnel with training to address relevant security risks; and that key information security personnel take steps to maintain knowledge of changing information security threats and countermeasures
  • Written incident response plan designed to promptly respond and recover from any security event affecting the confidentiality, integrity, or availability of customer information
  • Qualified individual to regularly, and at least annually, report in writing to an organization’s governing body (e.g., board of directors) regarding the status and material matters of the information security program
  • Regularly test or otherwise monitor the effectiveness of the safeguards’ key controls, and conduct required penetration testing annually and vulnerability assessments at least every six months and whenever there are material operational or business changes

Given the expanded definition of “financial institutions,” some of these organizations may be unfamiliar with the extent of these requirements, and even those familiar with GLBA previously must be ready to comply or face the consequences.

What are the penalties for non-compliance with GLBA?

Whether it’s GLBA, Regulation F, or any of the numerous state laws, companies can face serious penalties for compliance failures—monetary, reputational, and even criminal. When it comes to GLBA, non-compliance penalties include:

Section 5 of GLBA grants the FTC the authority to audit policies to ensure they are developed and applied fairly—all the more reason to follow the Safeguards Rule’s provisions of self-audits and testing. 

Learn More About Compliance and Collections

Now that you have the breakdown of the Gramm-Leach-Bliley Act updates to the Safeguards Rule, are you familiar with the other laws and regulations governing debt collection? Check out our Collections & Compliance resources to see what other regulatory guidelines may impact your business or schedule a consultation to get started»»

Call-and-Collect vs Digital-First Engagement for Debt Recovery

By on June 1st, 2023 in Compliance, Customer Experience, Industry Insights, Product and Technology, User Experience

Outbound calling has been the main mode of collections for decades, but the cost of a call center or in-house full-time employees (FTEs) making calls is no longer justifiable when most consumers simply don’t answer the phone, on top of the mounting compliance restrictions limiting opportunities to call in the first place.

But outbound dialing isn’t completely obsolete—digital-first omnichannel strategies can turn traditional call-and-collect operations around by integrating new digital channels into the communication mix.

Let’s compare traditional outbound calling methods versus a digital-first approach in three key areas impacting your business’s ability to collect more, faster:

  • COST
  • COMPLIANCE
  • CONSUMER PREFERENCES

Get even more statistics and data in our latest eBook — Why Evolve from Outbound Calling to Omnichannel Engagement? Cost, Compliance, & Consumer Preferences — available for download now»»

COST: Call-and-Collect

The cost to collect has been on the rise for traditional methods for years, whether you outsource to a call center or have FTEs dialing the phones.

One reason for this rise is based on the fact that many lenders still practice old strategies to prioritize contacting customers based on their risk profiles, balance, and average days delinquent—completely missing portions of their portfolios. Factoring in propensity to pay is important to successful engagement, but it means that agents’ time is focused on only a small portion of accounts, leaving potential repayments on the table.

Add in the overhead costs, inflation, and hiring challenges of using agents as first attempts at engagement and watch the expenses continue to climb past what you’re able to collect through outbound calling.

COST: Digital-First Omnichannel

Right off the bat, digital-first shows the cost of collections can fall by at least 15%.

Since digital is infinitely scalable, this communication tactic can touch every single account, regardless of scoring models—unlike human dialers who can only physically call a certain number of accounts on any given day. Going digital-first cuts down on the time billed for making repeated outbound calls that are never answered or returned, and it allows agents to interact with customers that want to speak directly to a person.

Overall, digital-first has shown to boost customer engagement by 5x, the first step towards repayment.

COMPLIANCE: Call-and-Collect

It’s no secret that it’s increasingly complicated to reach customers with all the legal communication restrictions.

While all debt collection communication is subject to compliance rules, outbound calling has specific laws and regulations that can carry costly penalties for non-compliance—and it’s only becoming more complex with new state-specific rules rolling out right and left. But no matter where your business is doing business, if you’re making collection calls you must follow these federal guidelines:

  • Inconvenient Time Rule: prohibits calling before 8am or after 9pm
  • Regulation F’s 7 and 7 Rule: Cannot call more than seven times within a seven-day period
  • Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act) tagging legitimate businesses as spam
  • FCC Orders further restrict dialing to landlines and include opt-out requirements for prerecorded voice messages

But there is a more streamlined way to ensure your collection communications are following all the rules: enter code-based compliance.

COMPLIANCE: Digital-First Omnichannel

Code-based compliance works by programing rules that ensure all communications fall within all federal and state laws and regulations, such as:

  • Frequency and harassment restrictions
  • Consent requirements*
  • Disclosure requirements

This digitally designed approach to compliance greatly reduces the opportunities for human error that are bound to occur in more manual processes. Additionally, the digital-first approach allows companies to continue to collect during times that calling would violate certain regulations, like the Inconvenient Time Rule. In fact, 25% of payments come in after 9pm or before 8am (the determined inconvenient times), since these hours can actually be more convenient for consumers to catch-up on digital communications they received throughout the workday.

*Generally, there is no requirement in the federal law to send debt collection communications by email, though some states are more restrictive. This is not legal advice, please consult an attorney for guidance on your unique circumstance.

CONSUMER PREFERENCE: Call-and-Collect

46% of consumers want to be reached through their preferred channels—so what are today’s consumers’ preferences?

Here’s a hint: phone calls aren’t at the top of the list.

And today’s Right Party Contact rates show it, ranging between just 0.5% – 4.0%. And out of those that do answer the phone, 49.5% of consumers take no action after a collection call. The old call-and-collect tactic may actually do more harm than good if compliance rules are ignored: out of the communication tactic complaints received by the CFPB in 2020, over half complained of frequent or repeated calls.

CONSUMER PREFERENCE: Digital-First Omnichannel

So if phone calls aren’t consumers’ preferred method of communication, then what is? For 59.5% of consumers, email is their first preference when it comes to debt collection communications. This is especially important considering that first contacting a customer through their preferred channel can lead to a more than 10% increase in payments.

This digital preference isn’t surprising since nearly nine in ten Americans are now using some form of digital payments—why would they expect collections to be any different? 14% of bill-payers prioritize payments to billers that offer lower-friction payment experiences, and digital is often preferred because of it. Digital communications are easily controlled by consumers and are tightly managed by service providers with built in mechanisms to prevent harassment (like with code-based compliance), which we know has historically been a challenge for call-and-collect practitioners.

Digital-First is the Future of Collections

And it’s here today, working for TrueAccord clients and customers.

At TrueAccord, we find that more than 96% of customers resolve debts without any human interaction when digital options are offered—reducing costs associated with outbound calling, lowering risks with code-based compliance built in, and delivering an experience that consumers prefer.

Get even more statistics and data in our latest eBook — Why Evolve from Outbound Calling to Omnichannel Engagement? Cost, Compliance, & Consumer Preferences — available for download now»»

Ready to go digital-first with your debt recovery operations? Schedule a consultation to get started today!

Coast to Coast: the State of Privacy and Compliance in 2023

By on April 20th, 2023 in Compliance, Industry Insights, Webinars
Coast to Coast: The State of Privacy and Compliance in 2023

Disclaimer: The information provided in this blog post does not, and is not intended to, constitute legal advice. 

Protecting consumer privacy is not an unfamiliar concept in our industry and it’s something that should already be woven into our policies, procedures, and practices. With the rapid increase of state privacy laws across the United States, any company that collects, uses, transmits, or receives consumer data has to stay up-to-date on all related compliance issues.

In a previous webinar, Coast to Coast—the State of Privacy and Compliance in 2023, TrueAccord’s legal experts discussed the newest federal privacy laws and all the related compliance issues. Watch the full webinar on-demand now!

The passage of the FTC’s Safeguards Rule, amending the Gramm Leach Bliley Act (GLBA), has been a big topic in data security conversations across the financial services industry as businesses prepare to be in compliance on or before the extended effective date of June 9, 2023. Meanwhile, several states have actively been considering and passing new legislation requiring additional policies, controls, and practices not only in the data security space but also for data privacy and data breaches. It is important for Chief Information Security Officers, Privacy Officers, and Chief Compliance Officers to stay on top of this legislation, as well as Chief Executive Officers since we have seen many federal and state actions naming the CEO in their individual capacity for failing to properly secure and protect data or to properly delegate these responsibilities to the appropriate persons within their organizations. 

**Please note this article is not legal advice. This is not an exhaustive list of all laws. You should consult a lawyer if you have questions about federal and state data security, privacy or breach laws.

Data Breach Laws

All 50 states have data breach notification laws on the books. In 2022, 19 states considered enhancing their data breach laws.

Those states that passed revised data breach laws, tightened up notification timelines, added additional definitions of what constitutes personal information, and expanded the notification requirements to include additional state agencies. For example, Arizona’s law HB 2146, amending Arizona Revised Statutes section 18-552, not only requires that notification be made to consumers but also to the Director of Arizona’s Department of Homeland Security. If the breach impacts more than one thousand people, then the law requires the notification also be given to the three largest nationwide credit reporting agencies, the attorney general, and now the Director of Arizona’s Department of Homeland Security. 

While most states are shortening the time frame in which a consumer must be notified of a data breach to 45 days or less, some of these laws include exceptions or a short list of situations in which a delay in notification is permissible. For example, Indiana’s revised law, H.B. 1351, amending Indiana Code 24-4.9-3-3, limits a permissible delay in notification three circumstances: (1) when the integrity of the computer system must be restored, (2) when the scope of the breach must be discovered, or (3) when the attorney general or a law enforcement agency asked to delay disclosure because disclosure will impede a criminal or civil investigation, or jeopardize national security.

Both Maryland (H.B. 962, amending Maryland Personal Information Protection Act and section 14-3501 of the Annotated Code of Maryland)and Pennsylvania (S.B. 696, amending the Pennsylvania Breach of Personal Information Notification Act) expanded the definition of “personal information” to include medical and health information, including a definition of “genetic information” in Maryland’s law.

Since the webinar, Utah Governor Spencer Cox signed into law Senate Bill 127 on March 23, 2023, which amends the state’s data breach notification statutes. The amendments go into effect May 2, 2023.*

Along with updates to states’ laws, Federal regulators are also providing additional guidance too. For example, the Office of the Comptroller of the Currency (OCC) recently released more information regarding when banks need to know from their vendors about data breach including ransomware notifications.

Data Privacy Laws

In addition to creating and updating laws to help consumers in the event of a data breach, states have also been enacting laws dedicated to protecting consumer privacy. There are six states with comprehensive data privacy laws: California, Connecticut, Colorado, Iowa*, Virginia, and Utah. These laws give consumers various rights over their personal information, such as the right to know what information companies collect and use, a right to correct their information, a right to opt-out of the sale of such information, and a right to request deletion. 

In 2022, Congress introduced a federal privacy law, HR 8152, the American Data Privacy and Protection Act; however, it did not make it to the finish line despite having bipartisan support. It contained some preemption of state privacy and data protection laws, which would have been a relief to many companies navigating the existing patchwork of state laws.  As of January 2023, many states have introduced privacy-related bills and this is likely to continue throughout the years to come. 

California took the privacy law lead in passing the California’s Consumer Privacy Act of 2018 (CCPA) that went into effect in January of 2020 to protect the use and sharing of personal data. California recently expanded the CCPA with the California Privacy Rights Enforcement Act (CPRA) that took effect on January 1, 2023. The law created the new California Privacy Protection Agency and gave it the power, authority, and jurisdiction to implement and enforce CRPA. Additionally, businesses must regularly submit their risk assessment on the processing of personal information to this new agency. 

The four other states that followed suit have substantially similar laws with broad definitions of personal information. These laws typically apply to persons that conduct business in the state and processing a set minimum of consumer data records (typically 25,000 or more) or businesses who earn at least 50% of their revenue from the sale of consumer data. 

These laws give consumers various rights, such as the right to access their personal data, correct inaccurate personal data, delete personal data, in certain circumstances, obtain a copy of the personal data they previously provided to a controller, opt-out of the processing of their personal data if related to targeted advertising, sale of personal data or certain profiling activities, appeal a controller’s refusal to take action on a request, and submit a complaint to the attorney general if an appeal is denied. Interestingly, Colorado’s law makes clear that a consumer’s consent is not valid if obtained through the use of a “dark pattern.” 

These laws do not give consumers a private right of action but are enforced by the state’s attorney general with civil monetary fines calculated per violation. These laws also contain exemptions for data already protected by other laws, such as HIPAA, FCRA, and GLBA.

Virginia’s law took effect January 1, 2023. Both the Connecticut and Colorado Data Privacy Acts will go into effect July 1, 2023. The Utah Consumer Privacy Act takes effect December 31, 2023. The Iowa privacy bill (SF 262) was signed into law by Gov. Kim Reynolds on Tuesday, March 28, 2023. The legislation is set to take effect Jan. 1, 2025.*

Best Practices for the Future of Data Security & Privacy 

Having good security practices in place is not only beneficial for both consumers and businesses, but is absolutely critical to stay compliant with all the new laws and amendments being introduced. 

So what are some of the best privacy and security practices to implement to protect customers, companies, and stay compliant? 

  • Practice data minimization.
  • Know where personal information lives at all times by creating a data map of where the data goes and is stored throughout your systems, which includes knowing your vendor’s data security and privacy practices and controls. 
  • Know who has access to personal information and routinely examine if that access is necessary to complete that job function.
  • Be intentional with how data is organized and stored so it can be easily segmented and treated differently if need be (think network segmentation). 
  • Have a public facing Privacy Notice–and make sure it accurately reflects your practices for use, collection, deletion and correction.
  • Conduct an annual data security and privacy risk assessment to continually reassess areas for improvement and where you may need additional controls.
  • Ensure contracts with parties whom you receive and/or give personal information to specifically address each parties’ obligations and restrictions for how personal information is used, shared, disclosed, stored, and sold (if permitted).

Compliance with data privacy and data security requirements will continue to progress as new laws and regulations are passed. Best practices will continue to evolve as well, as we continue to learn more about the expectations from Federal and state legislators and regulators, and as companies navigate evolving threats and vulnerabilities. Watch the full Webinar: Coast to Coast— the State of Privacy and Compliance in 2023 here »»

Learn more in our Compliance & Collections Resource Center or schedule a consultation today! 

Footnotes: 

*The Iowa privacy bill (SF 262) was signed into law by Gov. Kim Reynolds on March 28, 2023 after TrueAccord’s Coast to Coast webinar. 

*The data breach law for Utah was passed on March 23, 2023 after TrueAccord’s Coast to Coast webinar

An email is less intrusive than a phone call, finds N.D. Illinois while granting TrueAccord’s motion to dismiss

By on April 12th, 2023 in Company News, Compliance, Customer Experience, Industry Insights, User Experience

By Katie Neill & Steve Zahn

A court victory by TrueAccord Corp. (TrueAccord) in the Northern District of Illinois continues to showcase the benefits of digital collection as the court found receiving an email about a debt is less intrusive to consumers than receiving a phone call. Messer Strickler Burnette represented TrueAccord and filed the briefing in the case.

In the Branham v. TrueAccord opinion, the court granted TrueAccord’s motion to dismiss finding that the alleged injuries claimed by the plaintiff—undue stress and anxiety, financial and monetary loss, uncertainty as to how to proceed about the debt, and a harm that “bears a close resemblance” to invasion of privacy—are insufficient to establish standing for a Fair Debt Collection Practices Act (FDCPA) claim.

Plaintiff’s Allegations

Plaintiff alleged that TrueAccord violated the FDCPA by contacting her twice by email after having received notice that she was represented by an attorney. TrueAccord had no record of receiving a notice of attorney representation from the plaintiff. However, when deciding on a motion to dismiss like this, the court must rely solely on the facts and allegations in the complaint and consider them as true, whether or not they are.

In the complaint, the plaintiff included a laundry list of alleged injuries suffered as a result of receiving the two emails from TrueAccord. These injuries included:

  • “Actual” financial and monetary loss without any specifics
  • Confusion on how to proceed with TrueAccord’s debt collection attempts due to “misleading statements”
  • Undue stress and anxiety as well as wasted time, annoyance, emotional distress, and informational injuries
  • A harm that “bears close resemblance to” invasion of privacy

Plaintiff Did Not Allege a Concrete, Particularized Injury

In its decision, the court shot down each of these alleged harms and found that the plaintiff failed to properly plead a concrete, particularized injury as the U.S. Supreme Court required in Spokeo, Inc., v. Robins. 

Specifically, the court found:

  1. Unlike telephone calls, two unwanted emails are insufficient to confer standing and wouldn’t be “highly offensive” to the reasonable person.
  2. Alleged physiological harms (e.g., emotional distress, anxiety, and stress) are abstract harms and not concrete enough to support standing without a physical manifestation of such harms.
  3. Vague and conclusory statements that the plaintiff suffered financial harm without any allegations of facts to support that alleged harm are insufficient.
  4. Attorney fees for bringing suit on a matter cannot be the sole basis of standing to bring the matter; to do otherwise would permit any plaintiff without standing to create it by retaining counsel.
  5. “Wasted time” is not a sufficient harm for standing where no facts are alleged to support the claim.
  6. The risk of an invasion of privacy without an actual invasion of privacy is too speculative and not sufficient to confer standing.

Sophisticated Omnichannel Communication Strategies

This decision is another step forward for the use of email in debt collection as the consumer-friendly way. It also showcases the need for mindfulness when implementing an omnichannel communication strategy. Notably, while the court found a couple of emails are less intrusive than a phone call, it also stated that text messages, voicemail, and calls are different as they “are sufficiently intrusive on an individual’s peace and quiet” to support standing. Using a sophisticated omnichannel strategy helps debt collectors reach consumers at times that are right for the consumer and through the right communication channel, which ultimately creates a non-intrusive consumer experience.

Schedule a consultation to learn more about how email and an omnichannel approach can help their business’s collection efforts today»»

Q1 Industry Insights: Economic Stressors Persist while Pandemic-era Benefits End

By on April 5th, 2023 in Industry Insights

It’s tax season again, which can mean tax refunds for consumers that have historically been leveraged to stabilize finances or pay down debt. But with inflation and economic stressors persisting into the new year, many consumers are conflicted on their financial outlook and spending behavior is hard to predict. With uncertainties about how the end of various pandemic-era benefits will impact consumers, it’s more important than ever for creditors and collectors to implement strategies that consider consumer situations and preferences when attempting to collect.

Read on for our take on what’s impacting consumer finances and our industry, how consumers are reacting, and what else you should be considering as it relates to debt collection in 2023.

What’s Impacting Consumers and the Industry?

High inflation and interest rates persisted in the first quarter of 2023. While inflation eased for an eighth straight month in February at 6%, price increases rose sharply again on a monthly basis – prices grew 0.4% following a 0.5% increase in January, driven by higher gasoline and rent prices. In response, the Federal Reserve continued its battle against high inflation in March by raising its key interest rate by another .25% despite concerns around the turmoil that has shaken the banking system, landing it at 4.75-5%.

At the beginning of March, the federal government ended pandemic-era payments for low-income families on the Supplemental Nutrition Assistance Program (SNAP), causing nearly 30 million Americans to lose increased food stamp benefits. The extended payment boost was credited with keeping 4.2 million people out of poverty, with the average household expected to lose upwards of $95 per month in benefits with the program’s end.

In early Q2, another pandemic-era benefit around Medicaid will come to an end that will impact millions of consumers over the coming months. An estimated 15 million low-income Americans who were able to keep Medicaid coverage during the pandemic without needing to renew coverage or despite no longer qualifying will find themselves without health insurance. The Department of Health and Human Services estimates that in the end, more than 5 million children will have lost Medicaid, and predicts that Latino and Black beneficiaries will be disproportionately removed.

On the regulatory front, the Consumer Financial Protection Bureau (CFPB) hit the ground running for 2023 with new guidance on subscription fees, proposed rulemaking on non-bank company terms and conditions, and issued an annual report sizing up the three credit reporting companies. Directly impacting creditors and debt collectors, a January ruling from the District Court of Puerto Rico found that sending debt collection communications prior to any knowledge of a debtor’s bankruptcy filing is not a violation of the Fair Debt Collection Practices Act (FDCPA).

For businesses using pre-recorded messages to contact consumers, the Federal Communications Commission (FCC) published a new rule specifying that to be exempt from the Telephone Consumer Protection Act’s (TCPA) consent requirements, callers are limited to three pre-recorded non-commercial, non-telemarketing, or non-profit calls per 30 days, and would need to include an opportunity to opt out of prerecorded calls as part of the message. The final amended rule will go into effect on July 20, 2023.

Meanwhile, eyes are on the Big Apple as the New York Department of Financial Services (DFS) and the New York City Department of Consumer and Worker Protection are simultaneously engaged in amending their consumer debt collection rules. The DFS amendments would be an overhaul of its existing regulations and would include new debt types, while both amendments would introduce new disclosure requirements and additional restrictions on communications – specifically extending the existing requirement for direct consent to send email and text messages.

Key Indicators and a Heavyweight Court Decision

According to the New York Fed’s Quarterly Report on Household Debt and Credit, total household debt increased in the fourth quarter of 2022 by $394 billion (2.4%) to $16.90 trillion. Balances now stand $2.75 trillion higher than at the end of 2019, before the pandemic. In the same time period, the Federal Reserve reported that household net worth rose 2% to $147.71 trillion, driven by the value of equities holdings increasing $2.7 trillion offsetting a drop in real estate values by about $100 billion.

Consumers trying to make ends meet have continued turning to credit cards and other credit types to bridge the income to expense gap. According to the Federal Reserve Bank of New York, U.S. consumer credit card debt has increased to nearly $1 trillion. Credit card balances jumped more than $60 billion over Q4 2022, lifting the total amount of U.S. credit card debt to an all-time high of $986 billion, the report found. Home equity loans and lines of credit continue to be an attractive option to homeowners, though high interest rates may make opening a new account less appealing in 2023.

Diving deeper into credit cards, Experian’s March Ascend Market Insights report found that credit card balances, while slowing slightly from previous months as seasonally expected, were up 18.8% year over year in February 2023. Additionally, the report found that there were 7.2% more open credit cards in February than there were a year prior. These balances and new cards coincide with an increase in interest rates, raising the stakes for delinquent accounts. According to a January 2023 Bankrate survey, 35% of Americans carry credit card debt from month to month, up 6% from 2022.

And delinquency is trending. Experian also reports that early-stage delinquency is nearing or exceeding pre-pandemic levels for most credit products, with exceptions for first and second mortgages, Home Equity Lines of Credit and student loans. 30+ day past due accounts showed a 2.12% increase month over month in February, while 90+ days past due unit delinquencies for auto loans and personal loans are higher than they were in 2019. Additionally, roll rates show 1.06% of consumer accounts rolled into higher stages of delinquency in February. Revolving credit utilization continues to slowly increase, as well. The same month, 63% of consumers had utilized 20% or less of their revolving limits, while 21% of consumers had utilization of 60% or more.

The student loan forgiveness debate continues into 2023 as the nearly 19% of Americans with student loans wait to see how the case shakes out with the Supreme Court. If successful, many consumers will see their overall debt burden decrease. If unsuccessful, those consumers will see no reduction in their debt and will be responsible for resuming payments that were deferred or went into forbearance during the pandemic. A ruling is expected sometime in Q2 2023.

While student loan delinquency rates have been almost nonexistent since payments were paused, the delinquencies in mortgages, auto loans and credit cards have been trending back to pre-pandemic levels, which doesn’t bode well for student loan holders with other debts. When student loan payments resume, consumers will have to prioritize debt repayment, leading to higher delinquency rates for other debt types. For a data-driven look into this topic, read our latest report, “Consumer Finances, Student Loans and Debt Repayment in 2023”. 

Consumers Sending Mixed Signals About Finances

As the cost of living remains high, 62% of Americans said they are living paycheck to paycheck in February, up from 60% the month prior, according to the latest Paycheck to Paycheck Report from PYMNTS.com and LendingClub. According to Deloitte’s State of the Consumer Tracker, consumers are feeling slightly more optimistic about their personal finances and the direction of the economy, but are also signaling stronger intentions to save versus spend. 

But Bankrate’s 2023 Annual Emergency Savings Report shows that growing debt is hurting consumers’ ability to save, with 36% of Americans reporting having more credit card debt than emergency savings, the highest on record since 2011. The report shows that consumer concern about finances is high, with 68% of people surveyed worried they wouldn’t be able to cover their living expenses for one month without their primary source of income, including 85% of Gen Zers — the most concerned of any generation. Unsurprisingly, 74% surveyed said economic factors, inflation and changes in income and employment are causing them to save less right now.

What Does This Mean for Debt Collection?

So far in 2023, the economic landscape isn’t cutting consumers any breaks. With persistently high inflation and interest rates, the impending threat of a recession and a number of pandemic-era benefits coming to an end, consumer finances will likely be impacted and stretched in myriad ways this year. For lenders or collectors engaging with distressed borrowers, here are a few things to keep in mind:

1. Meet consumers where they are, compliantly. While regulations and compliance impacted both phone calls and digital channels in some way in 2022, our takeaway is that a one-size-fits-all approach to debt collection communication won’t work at scale in 2023. By using an omnichannel approach, collectors are more likely to engage a customer on their preferred channel and open the door for engagement. For a closer look at what using an omnichannel approach means in debt collection, check out our latest eBook.

2. Give consumers agency to engage on their own time. What do emails and online payment portals have in common? Consumers get to decide when and where they use them. Just because a call center operates from 9-5, doesn’t mean consumers do. Remember that everyone’s situation is different, including when they can (or want) to address their debt. 

3. Give consumers flexibility on repayment time and terms. Higher monthly financial obligations make it harder for consumers to absorb unexpected expenses or carve out funds for debt repayment. Patience will be key in engaging distressed borrowers – give them payment plan options for when and how much they repay, which could mean smaller payments, shifting payments to align with their cash flow schedule or skipping a payment without penalty so they can get back on track.

Why is Omnichannel Engagement Critical for Debt Recovery Today? Statistics, Success Stories, and Industry Insights

By on March 29th, 2023 in Customer Experience, Industry Insights, User Experience

Reaching consumers can feel harder than ever these days, so struggling to engage delinquent customers can leave some businesses ready to accept losses as just another “cost of doing business.” With 75% of Americans reporting that they will never answer calls from unknown numbers, even the most targeted scoring model for calling has low chances of recovering funds.

But the omnichannel approach—utilizing a combination of calling, emailing, text messaging, and even self-serve online portals—is the preferred experience for 9 out of 10 customers, according to a study conducted by UC Today. And it’s not just beneficial for consumers. The omnichannel approach has been shown to increase payment arrangements by as much as 40%!

So integrating an intelligent digital communication strategy with traditional call-and-collect or letters sounds like a smart plan, but why is it more important now than ever before?

Let’s look at why today’s economic landscape makes omnichannel engagement critical for collections and how your business can get there.

Delinquencies are Rising—And Call Centers Can’t Keep Up

The first quarter of the year revealed that Americans have almost reached $1 trillion in credit card debt, breaking a record set in 2019. Fueled by inflation and higher interest rates among other economic factors, some card issuers’ charge-off and delinquency rates are also rising back up to their pre-pandemic levels.

So we know that delinquencies are on the rise in addition to new compliance regulations that have put greater restrictions on calling (such as the inconvenient times rule, 7-in-7 rule, among others), which put greater limitations on the reach call centers can actually have. Even using scoring models to focus on those who have the highest propensity to pay, consumer preferences have moved away from engaging through (or even answering) the phone.

Even if you know which delinquent accounts are primed for repayment, old school methods will never be able to reach them all efficiently in comparison to digital engagement.

On top of that, consumers are typically already carrying out financial transactions online—so why would a business expect their preferences to shift offline when it comes to handling another financial interaction? When a customer defaults on their account, it is a disruption to their lives to suddenly receive phone calls and letters regarding an account for which they previously only communicated via digital channels.

From our own experience, many of TrueAccord’s creditor-clients prefer a seamless transition to debt collection, and will even go so far as to prohibit TrueAccord from making any outbound calls or sending letters on their accounts because their customers have only ever interacted digitally.

It can even stifle the flow of information that helps consumers make informed decisions about their finances. According to the Pew Research Center, “reliance on smartphones for online access is especially common among younger adults, lower-income Americans and those with a high school education or less.” In fact, 87% of TrueAccord consumers visit our web portal from their mobile devices and tablets, not their desktop computers. Choosing not to engage via digital methods can hurt vulnerable populations of consumers who primarily conduct most of their affairs digitally.

But the answer to this challenge isn’t going 100% all-in on digital communications necessarily. There’s a better way to reach past-due customers and collect more, faster (and from happier people).

Enter the Omnichannel Approach

We’ve seen that call-and-collect operations have proven less successful over time, even using propensity to pay scoring models, but there is a time and a place for those traditional methods in an omnichannel strategy. Adding different technologies to your debt collection operation like email, SMS, and even self-serve online portals can actually enhance the hard work your call centers are already doing and make it overall more effective.

Why is the use of different channels—and more importantly a customer’s preferred channel—so critical for today’s debt collection efforts? The numbers speak for themselves:

  • 46% of consumers expect to communicate through preferred channels
  • Initiating contact with delinquent customers through their preferred channels can lead to a more than 10% increase in payments
  • Some banks have found digital communication channels can increase payment rates of customers in late delinquency by 30%
  • Lenders that have implemented digital-first solutions have seen their cost of collections fall by at least 15%
  • Traditional outreach methods like outbound calling elicited 18% fewer responses from customers with accounts 30 days past due who prefer digital communications.

The key takeaways from these studies go beyond just “going digital”—to see improvements in engagement rates, repayments, and operational costs you must communicate through the consumer’s preferred channels.

At TrueAccord, we’ve seen this approach’s success time and time again for our own clients and their customers.

Statistics and Stories from the TrueAccord Omnichannel Strategy

Almost all TrueAccord communications with consumers (93%) happen electronically with no agent interaction. The remaining 7% of consumers who do interact with an agent, send an inbound email or make a phone call to our inbound call center where any of our customer care agents are prepared to assist with their request. This is a more cost-effective and efficient use of agents’ time versus making outbound calls, which benefits both businesses and their customers, as one consumer told us on June 1, 2022:

“Thank you for not calling a million times and texting me and allowing me to pay this when I could.”

As described above, TrueAccord primarily sends digital communications to help consumers navigate and take actions at their convenience online, as this consumer told us on January 18, 2023:

“I like how you explain everything in detail by email and easy payment plans for people to regain their credit scores and to get back on their feet.”

In fact, more than 21% of consumers resolve their accounts outside of typical business hours (before 8am and after 9pm) when it is presumed inconvenient to contact consumers under the federal Fair Debt Collection Practices Act (FDCPA). If we relied solely on reaching consumers during a call center’s business hours, that is almost a quarter of consumers who wouldn’t engage and take the next steps in their repayment process.

Our omnichannel approach is compelling for our clients as well—and it’s proven to pay off. As Todd Johnsen, Senior Manager of Collections Vendors for Snap Finance, explained:

“This audience [consumers in debt] may have already had experiences with incessant collection phone calls, and they are used to avoiding them. I wanted to find an agency that was doing things differently. I knew that TrueAccord was using technology and digital channels in a way that other providers weren’t. What we saw was almost 25-35% better performance with TrueAccord, compared to the accounts we placed with traditional agencies.”

See what other clients and consumers had to say about their debt recovery experiences with TrueAccord in our case studies and resources here»»

The Recovery Opportunities are Ripe with the Omnichannel Approach

Omnichannel targeting is a more effective way of maximizing repayment and conversation rates by offering a level of service and personalization that customers have come to expect from companies in the digital age.

With this holistic communication strategy, you can engage with every single account while call center agents still deliver the human touchpoint that can never fully be replaced. Reach customers with the right message, through the right channel, at the right time that works best for them—whether through email, text, or with a real person ready to guide customers back to financial health.

Creating an effective omnichannel strategy can seem complicated, but it’s not with the right experienced partner. Schedule a consultation to discover our early-stage collections solutions and late-stage collection services!

Consumer Finances, Student Loans and Debt Repayment in 2023

By on March 21st, 2023 in Data Report, Industry Insights

The economy took a wild ride in 2022, and with interest rates continuing to rise, inflation expected to remain relatively high and household savings dwindling, 2023 could be just as challenging. As consumers battle high inflation and interest rates to afford necessities, budgets will be stretched and many will have to prioritize when and where they spend. Unsurprisingly, paying off debt will likely take a back seat to food, housing and transportation needs. But what will that mean for lenders and creditors?

In order to construct a comprehensive picture of the financial landscape for consumers with debt in delinquency, we analyzed data of thousands of consumers in debt collection to explore how they are positioned to handle financial stressors as well as how different financial burdens impact the repayment ability of consumers in debt collection, especially for those with student loans in this tumultuous economy. 

Key Takeaways from the Report:

  • Economic indicators show a rough road ahead for consumers
  • Resumed student loan payments will impact ability to pay debts – consumers with student loans have an average of $11,373 in non-student loan debt, or 92% more than consumers without student loans ($5,917)
  • Student loan holders increased their average number of open trade lines by 10.3% since 2020, while open trade lines decreased by 7.7% for non-student loan holders
  • Consumers with student loans have an average of $811 more in auto loan debt than those without student loans as of 2022
  • Engaging consumers with multiple debts requires understanding, personalization and patience in 2023

Download and read the full report for more insights.

Turning Roadblocks into Better Recovery Opportunities

By on February 1st, 2023 in Customer Experience, Industry Insights

Businesses and consumers are buckling up for a bumpy economic road in 2023, but your company doesn’t have to accept that these recovery roadblocks spell inevitable losses. With the right digital communication strategy you can turn challenges into opportunities and engagement into recovered revenue.

Let’s look at the roadblocks—and uncover the opportunities.

The Roadblocks Between Your Business and Better Recovery 

Delinquencies have been rising (and show no signs of slowing down). According to the latest Experian’s Ascend Market Insights report released in January 2023:

  • Overall balance delinquency rates increased 6.88% in December
  • 30+ day past due accounts showed a 3.94% increase month over month
  • Month over month views of roll rates show 1.05% of consumer accounts rolled into higher stages of delinquency in December 2022

And looking ahead, TransUnion forecasts serious delinquency rates of 2.6% on credit cards by the end of 2023, up from 2.1% at the end of 2022.

Additionally, it’s no secret that consumer preferences have changed. It’s becoming nearly impossible to reach consumers through traditional methods like outbound calling and letters.

  • 94% of unidentified calls go unanswered
  • 49.5% of consumers take no action after a collections phone call

But now “going digital” isn’t enough—consumers expect self-service, a dynamically personalized experience, and continuous optimization that helps them resolve debt on their own terms and according to their own preferences.

  • 46% of consumers expect to communicate through preferred channels
  • 72% of consumers say they only engage with personalized communications
  • 90% of customers globally expect brands or organizations to have an online self-service support portal

Turning Roadblocks into Omnichannel Opportunities

These ongoing trends could be perceived as challenges, and as a result, many businesses accept losses as a “cost of doing business”—but with the right strategy these roadblocks can actually be opportunities to drive optimization and better engagement.

If your business has been relying on only call center operations, it’s time to shift gears and move to an omnichannel approach—a more effective way of maximizing repayment and conversion rates by offering a level of service and personalization that customers have come to expect from companies in the digital age. An omnichannel strategy facilitates engagement with customers and enables them to self-serve while freeing up agents to talk to customers that need more assistance.

McKinsey found in a study of 1,000 delinquent customers that digital channels such as emails and text messaging drove higher repayment action rates vs traditional channels, like outbound calling. In some cases, traditional outreach methods elicited 18% fewer responses from customers with accounts 30 days past due who prefer digital communications.

And the benefits of communicating with consumers digitally continues:

  • 65% of consumers open at least one email
  • 35% click at least one link in an email
  • 25% visit links after 9PM and before 8AM “presumptively inconvenient times”
  • And predictions show that 61% of total interactions with a brand will be through messaging by the end of 2023

At TrueAccord, we’ve found that 96% of consumers who resolve their debt with us do so via digital self-service, without any human interaction. But don’t just take our word for it:

“This audience [consumers in debt] may have already had experiences with incessant collection phone calls, and they are used to avoiding them. I wanted to find an agency that was doing things differently. I knew that TrueAccord was using technology and digital channels in a way that other providers weren’t. What we saw was almost 25-35% better performance with TrueAccord, compared to the accounts we placed with traditional agencies.”

Todd Johnsen, Senior Manager of Collections Vendors, Snap Finance

Navigate 2023’s Roadblocks with Your Roadmap to Better Recovery

While the economic landscape may seem like there’s a rocky road ahead, consumers aren’t taking an entirely negative outlook. According to TransUnion’s Consumer Pulse study, 52% of U.S. consumers said they are optimistic about their financial future during the next 12 months.

Now is the time to focus on creating a better experience and supporting consumer optimism about their road to financial health. Discover your own path to helping customers move into repayment with our new eBook, Your Roadmap to Better Recovery in 2023 – available for download now»

Ready to get started? Schedule a consultation today!

The Resolution Funnel: How to Effectively Guide Consumers Through the Repayment Process

By on January 25th, 2023 in Customer Experience, Industry Insights, User Experience, Webinars

At TrueAccord, our goal is to meet customers where they are to personalize a strategy for each individual customer. We do this by sending them a communication via the right channel, using messaging that resonates with them, and making them an offer they can afford.

We’re able to achieve this thanks to insights from the 20 million customers. This includes data like what email and SMS messages drive the most engagement, which web pages are customers viewing the most, what is the ideal payment plan length, as well as where and when customers stop engaging with us. With every insight, we’re able to improve the overall consumer experience and help keep customers get back to financial health (and recover more efficiently and effectively in the process).

The Resolution Funnel

A funnel is built using a lot of data and a lot of consumer insights. It helps organize that data into a view of the customer’s journey within our product and allows us to identify areas where we can concentrate product improvements. Whether that’s making the website more user-friendly, promoting new and different channels, or utilizing our patented machine learning models—each is a different lever or strategy we can use at different stages of the funnel.

At TrueAccord, our funnel is tailored to fit our business needs while still getting all the benefits of understanding our customers’ behaviors to move them through the funnel, in our case to resolve their debt.

Here’s an example that gives you a good picture of how we think about the customer journey. We have two different funnels for two different clients we work with. You can see they’re fairly different in shape. At the top of the funnels you can see all of the debts placed. Next is reachability, which looks at how the customers were reached, and then if the customers acknowledged their debt, all the way down to when they resolved their debt. These funnels show that for Client 1 we should concentrate our improvements at the top of the funnel, while for Client 2 we need to look at improvements at the bottom of the funnel.

We can slice and dice the funnel in different ways to see how different customer segments are performing. This helps us identify what is working for different consumer segments and for different clients so we can see on a granular level what stages of the funnel to lean into to improve performance specifically for them.

Top of the Funnel

When planning strategies that will improve performance and customer experience at the top of the funnel, it’s important to make sure that the contact information for a customer is correct and that content is personalized in order to get engagement. The stages that make up the top of the funnel are: Debts Placed, Reachability, and Acknowledgment.

Debts Placed: All of the debts that are placed with the company.

Reachability: For the reachability stage, the goal is to reach the consumer and make sure that they’re receiving communication efforts which could be something like a customer opening one email.

Acknowledgment: This could be clicking on an email or SMS and visiting the company’s website, but it could also be from an interaction with customer support via phone or email.

Middle of the Funnel

The two stages we consider the middle of the funnel are: Active Consideration and Commitment. This is where the customer considers the options they have, chooses one, and then commits to a payment arrangement. By providing an online platform that’s easy to use and navigate through filled with helpful content, customers are more likely to self-serve.

Active Consideration: A customer visiting a payment form on the website or having the intent to pay.

Commitment: A customer signing up for a payment plan or agreeing to any other type of deferred payment.

Bottom of the Funnel

Lastly, we’ll cover the two bottom-of-the-funnel stages which are: the Progression and Resolution of the debt. In these stages, it’s essential to have a plan management system in place to help customers keep up with their payments as well as a plan in case they fall off and stop paying. The funnel ends once the customer passes through these last two stages and has paid off their debt.

Progression: A customer paying a portion of their balance either through partial payments or payment plans. Sometimes this stage is skipped if the customer pays in full or in a lump sum payment.

Resolution: The last stage of the funnel, where a consumer satisfies their agreement through paying in full, settling, or filing a valid dispute.

Effective Recovery Through the Resolution Funnel

The more you listen to your customers through their usage and their behavior, the more you can learn and improve your digital collection strategy. Funnels can be an effective tool when you’re trying to improve your performance and customer experience, which are key factors to getting customers through to repayment. It helps you segment customer groups and define how they move through your system and products so that you can focus your collection strategies on where they matter most.

Watch the full Resolution Funnel webinar on-demand to learn more about how TrueAccord gets insights on funneling customers through each phase of the repayment process.

Interested in seeing how you can funnel more customers through the repayment process? Schedule a consultation today!