Beyond the Word “STOP”: Why Businesses Need to Expand How Consumers Can Opt-Out of Communications

By on April 2nd, 2025 in Compliance, Customer Experience, Industry Insights, Machine Learning, Product and Technology, User Experience

In today’s digital communication landscape, businesses—especially those that use digital outreach to engage delinquent consumers to collect debts—are facing increasing pressure to ensure they respect consumers opting out of communications from a particular channel.

While the word “STOP” has been a widely recognized method for consumers to unsubscribe from text messages, the reality is that consumers may express their desire to opt out in various ways. And with the advent of accepting MMS (Multimedia Messaging Service) replies that allow for multimedia content like images, videos, and audio, along with longer text messages, consumers are bound to get creative.

On top of consumer preferences, new and upcoming regulations from the Federal Communications Commission (FCC) and the Consumer Financial Protection Bureau (CFPB) are making it crucial for businesses to go beyond just the word “STOP” and ensure they have a comprehensive system in place to honor opt-out requests promptly and accurately.

Keeping Up with the Evolving Regulatory Landscape

The FCC is currently revising its rules as part of efforts to reduce unnecessary regulatory burdens, particularly those that affect automated communications like debt collection calls and texts—a shift in policy could influence how businesses, especially those in debt collection, approach consumer opt-out requests.
Two FCC orders in particular have direct consequences for companies that rely on automated communications, including debt collectors:

1. The 2024 FCC Order:

  • Consumers can revoke consent for robocalls or robotexts in “any reasonable manner,” making it vital for businesses to broaden their opt-out options beyond a single keyword like “STOP.”
  • The revocation applies not only to the channel through which the request was made but also to any other forms of communication at that phone number.
  • Businesses must process these requests promptly, no later than 10 business days.

2. The 2025 FCC Order:

  • This order strengthens rules regarding call blocking, which may affect legitimate debt collection communications. It mandates that service providers block calls they deem “highly likely to be illegal,” based on their internal Do Not Originate (DNO) lists.
  • The risk is that legitimate calls could get mistakenly blocked, disrupting lawful debt collection efforts.

Going Beyond “STOP”: Why It’s Essential for Businesses

As these new FCC orders take effect, why else do businesses need to expand their opt-out processes? Let’s start by looking at existing regulations and requirements along with other factors that can impact an organization’s ability to engage consumers, collect debt, and ultimately their bottom line.

  • Compliance and Legal Risk: By honoring only “STOP,” companies may miss other legitimate opt-out expressions, risking violations of regulations like the Telephone Consumer Protection Act (TCPA) or the Fair Debt Collection Practices Act (FDCPA). Failure to comply can lead to legal consequences and damage to a business’s reputation.
  • Efficiency: In industries like debt collection, where high volumes of communication are involved, a flexible, automated opt-out process can ensure that no consumer request is overlooked. Implementing technology to track and process these requests quickly is key to maintaining a streamlined, efficient operation.
  • Technology and Innovation: The digital age demands businesses use advanced technology to manage consumer interactions effectively. Automating the opt-out process ensures that all channels are updated in real time, avoiding mistakes and minimizing delays.
  • Consumer Trust: Consumers are more likely to engage with a company that respects their preferences and responds to opt-out requests quickly. Offering various opt-out methods and honoring them promptly can significantly improve customer experience.

TrueAccord Leads the Way in Opt-Out Efficacy and Efficiency with RPA Bots

At TrueAccord, we understand that consumer opt-out preferences must be managed with the utmost care. Using Robotic Process Automation (RPA) and artificial intelligence to automate back-office operations helps ensure compliance, improved customer experience, and a more cost-effective way to engage and collect.

  • Automated Opt-Out Recognition: While many companies recognize the word “STOP” as an opt-out request, TrueAccord’s system goes further. We use AI tools to scan incoming messages for not just “STOP,” but also for variations like “revoke,” “quit,” “cancel,” and even unusual or colorful expressions of dissatisfaction. If a message contains any of these keywords, the bot automatically processes the opt-out request by unsubscribing the consumer from the SMS channel.
  • Real-Time Compliance: Our system, powered by HeartBeat—TrueAccord’s patented machine learning engine—ensures that consumer preferences are respected. If a consumer opts out of one communication channel, we ensure that all future communications to that particular channel are paused, preventing any further contact that could lead to complaints or violations.
  • RPA Efficiency: Thanks to our RPA bots, tasks that once took hours or even days for human employees to manage are now completed in a matter of minutes. For example, our bots can process large volumes of responses, automatically unsubscribing consumers or flagging accounts for further review, reducing the time needed to comply with opt-out requests and ensuring that no request goes unnoticed.
  • Advanced Reporting and Monitoring: We don’t just automate the opt-out process—we also track and report on all consumer interactions. This allows us to maintain a detailed audit trail for compliance purposes, ensuring that all opt-out requests are processed promptly and accurately.

TrueAccord is committed to staying ahead of regulatory changes and technological advancements. As the FCC’s rules continue to evolve, we are constantly refining our processes to ensure we are not only compliant but also providing an exceptional consumer experience.

What Does This Fish Mean to You? Navigating Opt-Outs Through MMS

When it comes to consumers opting out of receiving TrueAccord communications through MMS, consumers can truly get creative: photos, memes, emojis, songs, selfies, and more. While text-based responses can be scanned and filtered, MMS is trickier.

For MMS, the reviews need that human set of eyes. Why? Let’s use this actual consumer reply to a text message from TrueAccord that included the standard “STOP to opt-out” language:

What does this fish mean to you? Specifically in the context of debt collection communications with a business, what action do you think the consumer is trying to invoke?

While there are plenty of words and phrases you can program into a filter or scanner, this fish is not as easy to decipher the meaning. Automation takes the burden of basic reviewing off the shoulders of agents and allows bandwidth for examining the more creative responses and handling them appropriately.

So if your debt collection partner is only using a rudimentary scanner for opt-outs, it’s likely that unique opt-out requests are falling through the cracks—and that’s if that partner even has an automated process to manage replies and responses in the first place.

For businesses looking for a debt collection partner, this is a differentiator between choosing TrueAccord versus a competitor—our system is built on code-based compliance which allows us to communicate with consumers at a scale that’s unimaginable from traditional call-and-collect or DIY collection programs. The more traditional operations that do not have these automated processes are also unable to keep up with the variety of replies consumers send to opt-out. Even if they have automation to send out mass volumes of emails or text messages, do they have automation to handle the volume of replies within regulatory timelines? Do they actually offer efficiency and scalability—or are they opening you up new compliance risks around opt-outs?

Opt-In to a More Efficient and Effective Debt Collection and Consumer Communication Process

In the ever-evolving landscape of consumer protection and compliance, businesses must be proactive in managing opt-out requests. It’s no longer enough to rely on a single keyword like “STOP.” As consumer expectations and regulatory requirements evolve, so too must the tools and technologies used to manage opt-outs. TrueAccord’s cutting-edge automation and machine learning technology leads the way in ensuring that consumer preferences are respected, compliance is maintained, and operations remain efficient.

By embracing a more comprehensive, technology-driven approach to managing opt-outs, businesses can build trust with their customers, reduce legal risks, and stay ahead of the regulatory curve.

Ready to opt-in to a more efficient and effective debt collection and consumer communication process? Schedule a consultation today»»

FCC Orders to Take Effect While Comment Period to Identify Burdensome Rules Opens 

By on March 26th, 2025 in Compliance, Customer Experience, Industry Insights, Product and Technology

The Federal Communications Commission (FCC) is seeking public input on identifying FCC rules for the purpose of alleviating unnecessary regulatory burdens. In a public notice released March 12, 2025, the FCC announced the Commission is seeking comments on deregulatory initiatives to identify and eliminate those that are unnecessary in light of current circumstances. The FCC notice stated: “in addition to imposing unnecessary burdens, unnecessary rules may stand in the way of deployment, expansion, competition, and technological innovation.” Reply comments are due by April 28, 2025.

In the meantime, two FCC Orders that both impact the debt collection industry come into effect:

  • A 2024 Order released last February impacting revocation of consent to receive autodialed calls and texts and prerecorded or artificial voice calls. The 2024 Order conflicts with the CFPB’s Regulation F Debt Collection Rule about the scope of an opt-out.
  • And a 2025 Order released this past February aiming to strengthen call blocking of illegal calls. The 2025 Order may result in the blocking of lawful debt collection calls and texts.

Quick Note: These FCC rules are about the Telephone Consumer Protection Act (TCPA), which applies only to calls and texts made by an automated telephone dialing system (ATDS) and prerecorded or automated voice calls (aka robocalls or robotexts).1 If you do not use an ATDS to make calls or texts, and you don’t use prerecorded or automated voice calls, these Orders do not apply to your communications.

I. 2024 Order – Special Revocation Rules

On February 15, 2024, the FCC published an order adopting rules which impact text messaging and outbound dialing using an ATDS as well as calls made with prerecorded or automated voice. Most provisions of the Order take effect April 11, 2025.2 Those provisions include:

  • Consumers can revoke consent by “any reasonable manner”
  • If consent is revoked it applies to both “robo texts” and “robo calls”
  • Companies must process do-not-call and consent revocations requests within a reasonable period of time not to exceed 10 business days of receipt

a. Revoking consent is super flexible.

The FCC Order establishes that consumers may revoke prior express consent for autodialed or prerecorded/artificial voice calls and texts in any reasonable manner. This means that companies cannot designate an exclusive means to revoke consent that precludes the use of any other reasonable method.

A non-exhaustive list of “reasonable” ways a consumer can revoke consent include:

  • Request made using an automated, interactive voice, or key press-activated opt-out mechanism on a robocall
  • A response of “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe,” or a similar, standard response message sent in reply to an incoming text message
  • Request submitted at a website or telephone number provided to process opt-out requests

If a consumer uses any reasonable method to revoke consent, the FCC considers that consent to be definitively revoked, and future robocalls and texts from that company must be stopped. If there is ever a dispute about whether a consumer reasonably revoked consent, the sender has the burden to show why they did not treat the consumer’s communication as a revocation.

b. Revocation applies to the number, not the channel.

The Order states that when consent for autodialed calls or texts is revoked, that revocation extends to both robocalls and robotexts regardless of the channel used to communicate the revocation. It is the FCC’s position that a consumer grants consent to be contacted at a particular wireless phone number or residential line, and therefore, consent revocation is an instruction to no longer contact the consumer at that number.

This FCC interpretation is different from the CFPB’s approach in Regulation F, which prevents debt collectors from contacting a consumer in a channel after the consumer opts out of communications in that channel. Under Regulation F, if a consumer opts-out from texts it does not require opting the consumer out of calls to that number. This FCC Order has a broader effect—if a consumer revokes consent to text by text, it requires opting the consumer out of all communications to that phone number (calls and texts).

c. Ten business days to process revocation.

The FCC now requires that companies honor opt-out/revocation requests within a reasonable period of time, not to exceed 10 business days of receipt. The FCC chose 10 business days since it was consistent with the timeframe to process revocation requests under the CAN-SPAM rules. However, the FCC made clear that it will continue to monitor advances in technology to see if faster processing times may be warranted in the future, and it explicitly stated “[w]e encourage callers to honor such requests as soon as practicable as a best practice.”

This particular provision is also at odds with the FDCPA, as the FDCPA does not contain language offering a reasonable processing time for opt-outs or any inbound requests (like cease and desist, notice of attorney representation, etc.) The CFPB did not provide any reasonable processing time for opt-outs in Regulation F.

II. 2025 Order – Enhanced Call Blocking Rules

On February 27, 2025, the FCC published an order seeking to strengthen the call blocking and robocall mitigation rules requiring all providers in the chain to block calls that are highly likely to be illegal based on a reasonable Do Not Originate (DNO) list. In the past, lawful debt collection calls have unfairly been blocked in these efforts. This Order has different effective dates but the earliest is May 2025.

a. Every provider must block illegal calls.

The FCC Order requires all providers in the call path to block calls that are “highly likely to be illegal” based on a reasonable DNO list. With this Order the FCC expands the requirement from prior Orders, now requiring all providers to block suspected illegal calls.

FCC does not mandate a particular list for providers to use. This is because providers know their own networks and may be better positioned to determine what types of numbers should be prioritized. As long as the provider can show that the list is reasonable, the provider will be in compliance with the Order. Providers must constantly update the lists and will want to show that their list is comprehensive to safeguard consumers.

This provision of the Order goes into effect 90 days after the order is published in the Federal Register. This order has not been published in the Federal Register as of the date of this blog post, but we should prepare for this rule to go into effect as early May 2025.

b. Special code for immediate notification of blocking to a caller.

The FCC has designed SIP Code 603+3 as the return call the provider must immediately use to notify callers when their calls are blocked based on “reasonable analytics.” This is the exclusive code for this purpose on IP networks. Using this code will ensure that callers learn when and why their calls are blocked based on reasonable analytics, which will allow these callers to access redress when blocking errors occur. This stems directly from the TRACED Act that requires the Commission to ensure that callers receive “transparency and effective redress” when their calls are blocked by analytics, and a single uniform code is the best way to achieve this transparency.

This requirement only applies when the call is based on analytics. If a call is blocked based on a DNO list, there is no requirement to provide immediate notification.

The Order further directs voice service providers to cease using the standard version of SIP code 603, or SIP codes 607 or 608, for this purpose.

The Order does not provide any additional protections for lawful callers because the FCC does not adopt any requirements for blocking based on reasonable analytics and the blocking notification rules adopted in the Order are expansions of our existing rules, rather than wholly new requirements. The Order states:

The record does not suggest that our current protections will be insufficient to protect lawful callers after these particular incremental expansions take effect. Moreover, and as discussed previously, we believe that the deployment of SIP code 603+ will provide significant benefit to callers that, when paired with our existing protections, are sufficient to protect the interests of callers.

This provision of the Order goes into effect 12 months (one year) after the order is published in the Federal Register. This order has not been published in the Federal Register yet, but it could go into effect as early March 2026.

c. No requirement to display caller name (yet).

The FCC declined to require the display of caller name information when a provider chooses to display an indication that caller ID has been authenticated. Although it does not adopt such a mandate, the FCC urges providers to continue to develop next-generation tools, such as Rich Call Data (RCD) and branded calling solutions, to ensure that consumers receive this information and welcome any updates industry has on its progress. The FCC noted that it may consider a mandate in the future, particularly if the timely deployment of such valuable tools does not occur without Commission intervention.

*This blog is not legal advice. Legal advice must be tailored to the particular facts and circumstances of each unique matter.

Citations:

  1. An ATDS or autodialer under the TCPA is a system that has the capacity to use a random or sequential number generator to either store or produce phone numbers to be called. To learn more about this read this blog.
  2. The Order also limited senders of text messages made using an ATDS to a one-time, revocation-confirmation text. This provision took effect in April of 2024.
  3. A SIP (Session Initiation Protocol) code, also known as a SIP response code, is a three-digit numerical code used to indicate the status of a SIP request or transaction, similar to HTTP status codes.

The Dangers of Dark Patterns in Digital Communication for Debt Collection and Best Practices to Avoid Them

By on March 11th, 2025 in Compliance, Customer Experience, Industry Insights, Product and Technology, User Experience

Striving to deliver positive consumer experiences is not just a best practice—it is becoming a more prominent component of compliance in debt collection, especially when it comes to consumer communication. As consumer preferences have shifted toward digital channels, the success of a business’s debt recovery operation (whether in-house or outsourced to a third-party agency) hinges on engagement through online platforms, emails, and text messaging.

However, without proper design or planning, digital outreach can cross a fine line becoming manipulative or even deceptive. These practices are known as “dark patterns,” and they can cause significant harm to both consumers and businesses. The danger of dark patterns lies not just in the unethical manipulation of users but in the long-term consequences of such tactics, from damaged consumer trust to legal ramifications.

But what exactly constitutes a dark pattern in digital communication? Let’s look at the official definitions and examples, the risks they pose to consumers, the consequences businesses can face, how to avoid inadvertent dark pattern design, and how TrueAccord has approached delivering consumer-centric debt collection communications since day one.

What Are Dark Patterns? Examples, Risks, & Consequences

Dark patterns are design practices that mislead or manipulate consumers into taking actions that do not align with their true intent or preferences. These tactics typically exploit psychological triggers, confusing language, and hidden choices to push users toward making decisions they might not otherwise make.

In recent years, dark patterns have drawn increased scrutiny from federal and state regulators. The Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) have made it clear that such practices are not just unethical but also illegal. According to the FTC, dark patterns are considered “unfair or deceptive” business practices under Section 5 of the FTC Act. In 2022, the FTC published a report titled “Bringing Dark Patterns to Light,” highlighting these manipulative tactics and the growing enforcement against them. The report honed in on four common dark pattern tactics:

  • Burying key terms and junk fees
  • Making it difficult to cancel subscriptions or charges
  • Tricking consumers into sharing data
  • Misleading consumers and disguising ads

In addition to the focus areas within the FTC’s report, some other examples of dark patterns in digital communication include:

  • Confirm-shaming: Using guilt-inducing language to discourage consumers from unsubscribing or opting out, such as “Are you sure you want to miss out on this exclusive offer?”
  • Trick buttons: Designing “unsubscribe” buttons to look like “continue” or “learn more” buttons, leading users to click on something they didn’t intend to.
  • Urgency tactics: Creating a false sense of urgency by suggesting a limited-time offer is about to expire, even when it isn’t.
  • Pre-checked boxes: Adding pre-ticked boxes for additional services or subscriptions, requiring users to actively opt-out to avoid unwanted charges.

These tactics are not just annoying for consumers—they also undermine trust in the brands that use them. In the context of debt collection, where trust is already fragile, dark patterns can have a particularly devastating impact. Dark patterns can cause businesses to lose credibility, customer loyalty, the ability for communications to get delivered through digital channels, and even revenue. When consumers feel manipulated, they may report a company’s emails as spam, impacting deliverability and overall the effectiveness of digital engagement.

The risks of dark patterns go beyond consumer dissatisfaction and lower email open rates—they can lead to significant legal and financial consequences. Various laws, including the Consumer Protection Act of 2019 and regulations by the California Privacy Protection Agency, explicitly prohibit the use of dark patterns in obtaining consent for data collection. Violating these laws can result in penalties, along with further damage to a company’s reputation in the eyes of the consumer.

In the long run, the use of dark patterns in digital communication risks creating a negative feedback loop: the more consumers feel misled, the less likely they are to engage with the business, and the less effective digital communications will be. This is why it’s crucial for companies to adopt transparent, user-friendly practices.

How to Avoid Dark Patterns

Avoiding dark patterns is not just about following the law—it’s also about fostering trust and transparency with consumers. Here are some key strategies to ensure your digital communications are free from manipulation:

  • Be Transparent: Clearly disclose all costs, fees, and terms. If there are any charges involved, they should be easy to find and understand.
  • Use Clear, Honest Language: Avoid language that might mislead or confuse consumers. Be direct and straightforward.
  • Avoid Manipulative Language: Never use guilt-tripping or fear-inducing tactics to push consumers into decisions.
  • Simplify the Decision-Making Process: Make it easy for consumers to make informed decisions by avoiding “choice architecture” that limits their ability to make fair choices.
  • Provide Symmetry in Choice: Ensure that privacy-protective options are as easy to select as less secure alternatives.
  • Make it Easy to Opt-Out: Ensure that unsubscribe links or opt-out buttons are clearly visible and easy to use, without hidden steps or confusing layouts.

How TrueAccord Leads the Way in Compliant Consumer Communications in Debt Collection

At TrueAccord, we take pride in being a leader in ethical and compliant digital communication since our inception in 2013. We’ve always believed that transparent, user-friendly communication builds trust, which ultimately leads to better resolutions for consumers and better repayment rates for businesses.

We make a concerted effort to ensure that our communications are free of dark patterns by focusing on both the design and messaging of our digital interactions. Our emails and text messages are carefully crafted to follow modern user experience (UX) standards, ensuring that they are clean, clear, and easily understood.

  • Brand Consistency: Every message we send out follows consistent branding with the right colors, fonts, and logos. This helps consumers recognize us as a legitimate company and reduces the risk of being mistaken for a phishing scam.
  • Clear Messaging: We prioritize clarity in our messaging. We make sure that everything we say is relevant, easy to understand, and free from confusing jargon or manipulative language.
  • Error-Free Communication: We carefully review our content for any spelling or formatting errors. Consumers often make snap judgments about the legitimacy of a message based on visual cues, so it’s crucial to maintain a professional appearance.
  • Easy Navigation: All our links work, and consumers are always redirected to the correct pages. If there’s ever an issue, we flag it quickly to ensure that the consumer experience remains seamless.
  • Compliance and Trust: We are committed to being fully compliant with regulations, but more importantly, we focus on building trust with the consumer. By providing clear, actionable, and honest communication, we can help consumers navigate their debt repayment process more effectively.

Moreover, our commitment to transparency ensures that every communication we send out, whether via email or mobile, is accompanied by clear disclosures to further legitimize our efforts and foster a stronger relationship with the consumer.

As mentioned above, a lot of the regulations that have come out specifically about dark patterns have been in recent years. But with over a decade of experience in digital debt collection, it has always been our duty at TrueAccord to ensure we are not inadvertently causing dark patterns in communications or any part of the repayment process—not because it’s a compliance requirement but because we know that when a consumer trusts and engages with your communications, you have better liquidation results.

Don’t Risk Dark Patterns—Partner with Experts in Collections & Compliance

Dark patterns are a serious issue in digital communication, and while they may offer short-term gains, they can have long-lasting consequences on a company’s reputation, legal standing, and customer trust. By avoiding these deceptive practices and focusing on transparent, honest, and user-friendly communications, businesses can build stronger relationships with their customers and avoid the legal pitfalls associated with dark patterns.

At TrueAccord, we have always been at the forefront of recognizing the importance of ethical communication in debt collection. By prioritizing transparency, trust, and compliance, we not only ensure a better experience for consumers but also achieve better results for our clients. After all, when consumers trust the process, they are more likely to engage and succeed in resolving their debts—making for a better outcome for everyone involved.

Ready to partner with an industry-leader in compliant digital-first debt collection? Schedule a consultation today!

Sources:

Balancing Compliance and Consumer Experience in Digital Debt Collection: Best Practices to Navigate the 2025 Landscape

By on March 4th, 2025 in Compliance, Customer Experience, Industry Insights, Product and Technology, User Experience

Over the past several years, federal and state regulators have started raising red flags about a significant trend in the debt collection industry: companies failing to deliver positive experiences for consumers or properly manage complaints and disputes. With growing scrutiny from agencies like the Consumer Financial Protection Bureau (CFPB), the Federal Trade Commission (FTC), and even the White House, it’s clear that ensuring a good consumer experience is no longer just a best practice—it’s a compliance requirement.

As we move further into 2025, it’s essential for debt collectors and businesses to find the balance between adhering to the myriad of regulations while maintaining a smooth and positive consumer experience through the repayment process. And while digital communication channels have become increasingly favored by consumers, mass blast emails and SMS campaigns don’t equal rave reviews or recovery rates.

Add on evolving compliance regulations and the modern debt collection challenges mount. While 2024 saw different governing bodies and providers make progress handing down guidelines and best practices for better consumer experience overall, regulations and legislation is still not always 100% clear on what is and is not acceptable for compliance.

So how can your debt collection strategy keep up with the 2025 compliance and consumer preference landscape? Let’s look at ways to navigate the challenges and increase liquidation rates as a result.

Staying on Top of the Shift Toward a Consumer-Centric Compliance Model

Traditionally, compliance in debt collection focused primarily on following established regulations, such as the Fair Debt Collection Practices Act (FDCPA) and Regulation F. However, recent regulatory actions are increasingly examining how businesses interact with consumers beyond the letter of the law and have emphasized that poor consumer experiences can even trigger legal violations. If a debt collector fails to manage complaints and disputes properly, it could result in potential violations of the Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) standards, or even the Dodd-Frank Act.

Even the use of emerging technologies is being scrutinized through the consumer experience lens: the CFPB has highlighted concerns over poorly monitored artificial intelligence (AI) or machine learning, specifically when it comes to consumer interactions. A poorly designed or maintained automated messaging system can lead to consumers getting “stuck” in automated loops, resulting in complaints and potential regulatory scrutiny or even rise to the level of a compliance issue.

Another area of increasing consumer frustration can be the process of opting out from receiving further digital communications. Automated messages that give consumers the ability to remove themselves from receiving further communications by replying “STOP” but do not account for a range of possible opt-out requests or replies can lead to complaints and trigger regulatory action.

The lesson is clear: compliance is not just about ticking boxes—it’s about delivering a consumer experience that’s transparent, responsive, and respectful. And with a smart approach, businesses can use technology to minimize compliance risk while enhancing the consumer experience.

Best Practices to Strike Balance Between Compliance and Consumer Experience

Understanding this focus shift and the nuances of ever-unfolding regulations still leaves us with the original question: how can your debt collection strategy keep up with the 2025 compliance and consumer preference landscape? While it is imperative to follow all laws and requirements in the collections industry, following the best practices below can help your organization prepare and provide the best consumer experience through the delinquency lifecycle as the regulatory landscape continues to evolve:

  • Implement robust compliance oversight programs, particularly when scaling digital outreach efforts
  • Establish clear policies and procedures around the use of AI, machine learning, and other emerging technologies in debt collection and digital communication, and continuously assess their impact
  • Map and monitor outreach across all communication channels holistically, ensuring that consumers do not get “stuck” in a loop or experience any disruption in their communication
  • Ensure any messaging systems appropriately handle variations in opt-out requests (like we mentioned above, “STOP” is just one way consumers might convey their opt out of SMS)
  • Automation can be used not only to send messages but also to ensure that every piece of communication complies with the necessary regulations
  • Partner with debt collection agencies that have experience successfully using digital communications compliantly

The key is to adopt a comprehensive approach that blends technology, consumer insights, and compliance best practices. By leveraging digital tools to monitor communications, mapping out consumer journeys, and staying vigilant with AI and machine learning systems, businesses can maintain compliance without sacrificing the quality of the consumer experience.

And TrueAccord has a proven track record as an industry leader in digital-first debt collection from both a compliance and consumer experience perspective.

The TrueAccord Difference

To start, TrueAccord is a licensed, bonded, and insured collection agency in all jurisdictions where we collect. We ensure compliance control, auditability, and real-time updates for changing rules and regulations, as well as adapting to shifting trends in consumer preference and behavior.

Our digital collections compliance process is controlled by code, ensuring that all regulatory requirements are met, while still being flexible to quickly adjust to new rules, case law, and consumer experience expectations.

Take the example from earlier about consumer frustration trying to opt-out: at TrueAccord, we’ve found that only 7% of consumers use the word “STOP” to opt out of SMS communications—but our team and machine learning engine, HeartBeat, account for the many other phrases consumers may use to opt-out, staying compliant and reducing consumer friction.

It’s important to remember that most compliance rules were written for the benefit of consumers. As we’ve seen from today’s consumer-centric compliance guidelines, the better we comply, the better the consumer’s experience should be.

Ready to partner with an industry-leader in compliant digital-first debt collection? Schedule a consultation today!

Using Letters in Omnichannel Debt Collection—Keeping Up with Compliance

By on February 18th, 2025 in Compliance, Customer Experience, Industry Insights, Machine Learning, Product and Technology, User Experience

Direct mail is the old-school method for reaching consumers regarding their debt, but over time several factors have reduced the effectiveness of letters in collection communications—consumer preference and cost being the most prevalent. But specific state compliance regulations and other use cases prove that “snail mail” still has its place in the omnichannel mix.

When are Letters Necessary in Collection Communications?

While the cost of physically mailing letters may be a deterrent to snail mail, businesses benefit when direct mail is used to meet compliance requirements. We’ll go into more detail around regulations in the next section.

Another benefit of mailing letters is most apparent when the delinquent account does not have a valid email address or phone number on file. Letters ensure that these individuals still receive crucial notifications regarding their accounts, preventing any potential oversight, and provide essential information related to their debt in a clear and organized manner.

Additionally, the formality of letters can be necessary to help raise awareness of outstanding debt for consumers that may not be as trusting of digital communications and choose to ignore phone calls. This is especially true for those who may not be as computer savvy or familiar with online financial transactions.

And just like with all other communication channels in debt collection, consumer preference also plays a role but in an even greater way with traditional letters: if a consumer clearly states that they only want to be contacted through physical mail (either to them directly or to their legal representation), businesses and collectors must abide. These types of requests lead to the main use case for letters…

The Main Use Case for Snail Mail: Compliance

The primary use case for using the direct mail channel is for compliance. Several laws, regulations, and governing bodies—including the Fair Debt Collection Practices Act (FDCPA), Regulation F, Consumer Financial Protection Bureau (CFPB), among others—define how, when, and what needs to be included in consumer communications around debt collection, and letters were the original initial compliant consumer communication.

Yet the prevalence of digital has forced these regulations to evolve, and today there is no federal law requiring consent to communicate via email vs direct mail.

But there are some exceptions to this general rule:

  • Some states/jurisdictions require consent to communicate via email and text, which must be obtained through physical letters and documentation.
  • In some instances, consent to send legally required notices electronically must also be obtained through physical mail.
  • Some states require certain legally required notices to be mailed.

See Success and Real World Results with TrueAccord

Understanding the nuances of compliance and when communications fall under certain laws can be challenging without legal experts keeping a finger on the pulse of these evolving regulations—but TrueAccord ensures success with code-based compliance so all our engagement channels meet the requirements for each unique account’s circumstance and know when letters are the right choice for outreach.

While our omnichannel strategy is digital-first, we understand that digital isn’t always the best or most viable option to connect with some consumers. Knowing when, where, and why a letter might be the ideal choice for consumer communication helps TrueAccord and our clients remain compliant and cost-effective. Depending on a consumer’s location and contact information, a letter may be the best bet to garner engagement.

With advanced code-based compliance and scrubbing capabilities, TrueAccord’s omnichannel approach proves even snail mail can still be effective in collections.

Want to know more about how the omnichannel approach and how each channel influences the effectiveness of a business’s overall collection strategy? Download our new eBook, Omnichannel Communication in Debt Collection: An In-Depth Look at Advanced Engagement Strategy by Channel now»»

Using SMS in Omnichannel Debt Collection—Digital Strategy Beyond Email

By on January 27th, 2025 in Customer Experience, Product and Technology, User Experience

For consumer engagement in debt collection, many organizations and agencies have moved away from outbound calling—but don’t discount reaching out to consumers’ phones just yet! Text messaging (referred to as SMS or short message service) is becoming a favored method for consumers to receive business communications.

It’s common knowledge these days that people tend to ignore phone calls from unknown numbers and often throw away physical letters without opening them, but they will also delete unfamiliar emails without reading them, too.

So if your digital communication strategy only includes email, consider this: consumers are nearly twice as likely (1.8x) to prefer texting to any other communication method. Gartner reports SMS open and response rates as high as 98% and 45%, respectively, compared to corresponding figures of 20% and 6% for email.

For successful debt collection operations, adding SMS into the digital mix to build an omnichannel approach (along with email, calling, letters, and self-serve options) boosts engagement and liquidation rates.

Why is SMS Critical in Collection Communications?

SMS allows creditors, debt collectors, and financial institutions to communicate with individuals in a brief and direct manner, more so than traditional methods such as letters or phone calls—or even email. SMS is a powerful tool for debt collectors looking to engage with consumers who might otherwise avoid other forms of communication. These messages can serve a variety of purposes, from notifying debtors of outstanding payments to reminding them of upcoming due dates or offering payment plan arrangements.

SMS offers several practical advantages for both debt collectors and consumers. The concise nature of SMS—limited to 160 characters—forces communication to be direct and to the point, ensuring that messages are clear and easy to understand. Consumers who may feel overwhelmed by lengthy phone conversations or complex emails often appreciate this streamlined approach.

Surveys have found that 85% of consumers state that they prefer to receive an SMS instead of an email or phone call and more than 55% said they prefer text messaging because it’s immediate, convenient, and allows them to quickly get updates—and that’s just the beginning of consumer preference statistics surrounding SMS communication:

  • 65% want their accounts, billing, and payment reminders sent to them as a text
  • 89% say they prefer texting with businesses over any other mode of communication
  • 97% of companies that have launched texting initiatives say those initiatives help them communicate with consumers more efficiently

And studies of overall communications from businesses show that consumers are 134% more likely to respond to a text than an email.

Use Cases and TrueAccord Success Stories

According to the Pew Research Center, 97% of Americans own a cell phone, and nearly the same percentage sends at least one text message each day, making SMS an already well-established communication method most consumers are familiar and comfortable with. By using SMS to reach out to delinquent consumers, debt collectors tap into a channel that’s not only widely accessible but also highly effective in terms of response and engagement. With its speed, convenience, and familiarity, expanding digital strategies to include SMS is critical for consumer preference.

Along with this preference and the corresponding better engagement rates, compliance is one strong case for using SMS in consumer engagement for collections. The implementation of Regulation F by the Consumer Financial Protection Bureau (CFPB) has helped modernize the Fair Debt Collection Practices Act (FDCPA) by focusing on electronic communications and giving guidance on how to properly use SMS as a channel.

SMS provides consumers with links directly to account portals where consumers can get more information, pay, dispute, etc. at a time that is convenient for them and without having to talk to an agent.

“This is my first time paying off a debt collection online by just receiving a text. I just received a text from the debt collector and I made a payment arrangement just by a few clicks. This way is just so much better and easier.” – Real feedback from consumer working with TrueAccord

Positive consumer feedback is just one part of the TrueAccord difference for this channel. TrueAccord goes beyond just adding SMS into the mix—our team digs deeper to ensure the best possible engagement in this channel. Similar to email deliverability, TrueAccord teams track SMS reachability, or the likelihood that a text message sent by a business actually reaches the intended recipient’s mobile device.

And just like with every approach in our omnichannel strategy, our machine learning decision engine, HeartBeat, guides optimal communication with the right message, right time, and right channel. From reminders to direct calls-to-action, SMS offers many benefits for both consumers and businesses thanks to the speed, convenience, and higher engagement rates towards debt resolution.

Want to know more about how the omnichannel approach and how each channel influences the effectiveness of a business’s overall collection strategy? Download our new eBook, Omnichannel Communication in Debt Collection: An In-Depth Look at Advanced Engagement Strategy by Channel now»»

Client Success Story: TrueAccord Delivers Industry-Leading Engagement, Repayment for Scale-Up BNPL

By on November 13th, 2024 in Client Success Story, Customer Experience, Product and Technology, User Experience

With its growing popularity, one Buy Now, Pay Later (BNPL) faced challenges with the complexity of managing late-stage collection—a hurdle many start-ups face since the majority of a scaling company’s resources are dedicated to bottom-line business goals rather than debt collection.

So as the BNPL continued to expand, accounts overdue by 90 days or more accumulated without a scalable strategy for resolution, making the BNPL vulnerable to revenue loss. But partnering with the experts at TrueAccord would set a plan in place with impressive liquidation and engagement results.

As their first debt collection provider, the BNPL leveraged TrueAccord’s decade-plus of experience to develop a comprehensive debt recovery strategy from the ground up. TrueAccord’s digital-first approach to collections was particularly appealing to the BNPL, aligning with their tech-forward, consumer-centric philosophy, and delivered on several key benefits:

  • Cost Savings
  • Automation and Scalability
  • Enhanced Consumer Experience
  • Compliance and Expertise

Through this partnership and late-stage debt collection strategy, delinquent accounts were managed thoroughly and efficiently—and their engagement rates were the first in a domino effect of improved results:

  • 45% Email Open Rate compared to industry average of 22.5%
  • 14% Email Click Rate compared to industry average 2.3%

Discover the impressive liquidation rates and detailed benefits TrueAccord provides in the full in-depth case study here»»

Ready to scale-up your debt collection strategy for better engagement and liquidation rates? Schedule a consultation with TrueAccord experts today!

Industry average statistic sources:

  • Hubspot
  • Campaign Monitor

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:

Consumers Prefer Self-Serve Options for Debt Repayment—and Businesses Cannot Afford to Ignore Consumer Preferences

By on October 17th, 2024 in Customer Experience, Machine Learning, Product and Technology, User Experience

Self-service portals are an empowering way to get consumers back on track. In fact, research from McKinsey found that consumers who digitally self-serve resolve their debts at higher rates and are significantly more likely to pay in full. Just take into consideration that surveys have found that four in 10 have used an online portal supplied by a financial institution for bill pay, while only a quarter have paid by phone, mailing a check, or in person.

But along with helping your bottom line, consumers just prefer these kinds of self-serve methods for payments.

Let’s dive even deeper into consumer behavior and preferences when it comes to handling payments and account management via self-service—and why organizations cannot ignore the numbers.

Self-Serve Preferences by the Numbers

The numbers don’t lie—more consumers want and use self-serve online portals for bill pay:

  • 60% of consumers prefer self-service options
  • 54% of surveyed consumers have used an online portal supplied by a biller
  • 47% prefer self-serve portals because of the convenience and flexibility

And businesses cannot afford to ignore these preferences:

  • 81% of customers want more self-serve options
  • 14% of bill-payers who prioritize at least one bill over others identified the ease of making payments as a key factor in that decision-making process
  • According to one study performed by McKinsey, a bank saw a 15% increase of cured accounts after implementing a self-service option
  • 70% of customers expect a company’s website to include a self-service application

Despite this data, a 2023 Transunion report shows that 64% of collections agencies don’t have self-serve capabilities, and simply increasing customer calling won’t improve contact and recovery rates.

But don’t worry—TrueAccord’s self-serve portal has proven to be a win for both businesses and their customers, with 98% of delinquent consumers serviced by TrueAccord resolving their debt without any human interaction.

TrueAccord’s Machine Learning Engine Powers a Better, Compliant Self-Serve Experience

At TrueAccord, we know that every consumer’s delinquency situation is unique and so are their repayment and engagement preferences. So from our initial outreach, we tailor our consumer communications using our patented machine learning engine, HeartBeat, to determine the right message, right channel, and right time to engage.

HeartBeat uses a machine learning model that looks at account properties and chooses a communication (written by experienced debt collection content creators) based on previous interactions with consumers that have similar characteristics.

This is important since studies show that 53% of consumers expect their financial provider to leverage the data they have about them to personalize their experience. From messaging that resonates to flexible payment options within our self-serve portal, TrueAccord uses advanced machine learning to drive the optimal engagement and repayment rates while working within both our client’s guidelines and regulatory requirements.

Our self-serve portal meets collections compliance rules while also meeting a consumer preference at the same time. When asked why they pay bills online, three in 10 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.

By following all compliance regulations and your business’s guidelines, our consumer outreach aims to drive the most engagement and commitment to repayment through the self-serve portal.

What Consumers Have to Say About TrueAccord’s Self-Serve Portal

We’ve looked at a lot of statistics supporting consumers’ preference for self-serve options, but let’s hear from real consumers that have used TrueAccord’s 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.”

And put quite simply, our consumers “love this online payment portal.”

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:

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: