Code-driven compliance is the future of debt collection

By on June 12th, 2020 in Compliance, Product and Technology

Compliance regulations in the debt collection industry are built to protect consumers in debt from potentially predatory practices and ensure an equitable collections experience. For debt collection agencies, this often requires building out entire departments dedicated to keeping the agency in line with ever-changing debt collection laws and regulations. These teams are committed to reducing risk wherever possible.

One risk that is built into traditional debt collection practices is the potential for human error in a contact center environment. Digital debt collection platforms, however, offer code-driven compliance solutions that range from supporting existing agents to operating largely without the need for agent intervention.

Digital compliance solutions

Agent support

Operations managers throughout the collections industry cite high turnover rates in contact centers as a major challenge. While the exact number changes drastically depending on who you ask, contact centers may see annual agent turnover rates as high as 100%, but properly training contact center agents takes time (at TrueAccord our training process spans a full six weeks). High turnover in a space that requires thorough training means that newer agents may make mistakes when navigating important and complex regulations.

Some of this concern can be alleviated through the introduction of a curated content management system that provides prompts. These systems can be built with pre-written responses that adhere to compliance guidelines that improve agent compliance performance. While this may help to reduce the risk, the consumer experience is less than ideal.

Code-driven digital-first debt collection 

Digital-first debt collection agencies and other debt collection software tools provide systems that allow for close control over what actions are taken and what messages are sent to consumers. These messages are carefully crafted by a dedicated content team, reviewed by a team of legal and compliance experts, and are easily accessible for auditing purposes. They are also then managed by the digital system once they are implemented. 

Most importantly, these messages are then integrated into a digital, consumer-driven payment experience. More advanced systems use artificial intelligence and machine learning to customize a unique customer experience that is optimized for engagement and liquidation.

Compliant content creation

Pre-approved consumer-facing content

Building a digital debt collection system starts with creating compliant and adaptable content. Every email, text message, and landing page in a digital ecosystem is created by a team of dedicated content writers who draft and experiment with different approaches to encourage customer engagement. The guidelines used to draft these messages are shaped by collections laws, policies, and regulations. 

Are you interested in learning more about the content creation process? Here’s an interview with one of our content managers all about engaging with empathy.

Teams can also draft content that meets the needs of individual clients with specific brand considerations. Once the content is drafted, it is processed and reviewed by a team of compliance experts prior to being added to a content repository that the digital system can draw from.

Scalable compliance review process

The next step is to have a team of legal and compliance experts from within the debt collection agency review the content to ensure its adherence to the same regulations. Based on the client’s preferred level of involvement and resources, such a review process may also include a compliance team within the client’s organization. This process lays the foundation for compliant communication down the line.

Easily audited communication history

The content auditing process comes further down the line, but it is important to build that foundation early for the same reason stated above. Traditional call-and-collect debt collection agencies may record voice calls and even provide automated transcriptions of these calls. Unfortunately, these processes are not perfect because auditing activities can only review sample cases. Digital systems are able to accommodate a full audit-specific interface.

At TrueAccord, 96% of consumers resolve their accounts without communicating with an agent, so the vast majority of communications that exist are entirely automated and recorded. Compliance staff can easily search for individual accounts to review and evaluate all collections activity across multiple channels. Digital systems overall offer improved data retention and tracking to provide a clear picture of performance. 

Because the system saves this data, it’s easy to investigate how it responded to a particular message, as well as why it made a specific decision. When these communications are controlled by code, decisions are easy to trace and replicate.

How do these steps lay the foundation for a scalable digital compliance system?

Once content is in place, and there is an established process for reviewing it, digital debt collection platforms can connect to consumers. At TrueAccord, our machine learning engine, Heartbeat, is able to draw from our content library and improve communications with a consumer over time. Digital systems reach out to consumers when and how they prefer and these communication decisions are driven by data, not by individual agent decisions or potential biases.

Digital systems reach out to consumers when and how they prefer and these communication decisions are driven by data, not by individual agent decisions or potential biases.

Digital debt collection systems rooted in machine learning are dynamic. The content they choose to use for an individual consumer is determined not only by historical data but how a consumer responded (or did not respond) to previous communications. Every single message in the system is vetted to meet compliance standards, and the review process is always ongoing to maintain those same standards.

At any point in the customer lifecycle, a consumer can opt-out of communications by replying to a text message or by clicking a link in an email that lets them easily unsubscribe from future communications using that channel. Each email and payment page also provides a link for consumers to request debt verification via a few simple online steps.

Coded compliance continues to scale

As the system scales and communicates with more consumers in this way, it’s able to continually enforce compliance without needing to be retrained because it is built to be compliant from the ground up. Built-in compliance checkers can prevent the use of contact methods that the consumer has unsubscribed from or ensure they do not receive a payment offer that the creditor has not approved. 

Any compliance updates—such as new rules from the Consumer Financial Protection Bureau’s proposed rules—can be implemented securely and quickly at a company-wide scale rather than retraining on an agent by agent basis. 

An improved, more secure consumer experience

Collections regulations and laws are largely driven by a need to protect consumers from bad actors in the industry. Digital debt collection empowers consumers to manage their accounts at their own pace and communicate using their preferred communication channels.

By evaluating content before it is ever sent and programming a platform that delivers unambiguous content you can reduce confusion and improve the user experience. Clear, compliant messaging enables consumers to resolve their accounts through self-service without added support. This leads to a dramatic reduction in consumer complaints, and in TrueAccord’s case, many positive online reviews

A code-driven future for debt collection

Code-driven compliance offers predictable, pre-approved, and consistent collections methods. Coupling digital platforms with machine learning creates a system that improves over time and optimizes for a better user experience, guided by consumer preferences and shaped by compliance guidelines. This minimizes the need for agents to manage an account from start to finish and instead allows them to focus on more complex customer cases.

New technology is often seen as a risky investment, but digital debt collection systems offer more compliance security and more transparency—for consumers and creditors—than traditional debt collection agencies. Digital debt collection solutions not only evolve to meet consumer needs, but they can also continually adapt to changing regulations and quickly meet compliance requirements. 

Do you want to see the power of a code-driven compliance platform in action? Reach out to our team today to see what this looks like at TrueAccord.

What role does social media play in debt collection?

By on April 8th, 2020 in Industry Insights

Social media in the business world is typically used in a few select ways: individuals that use platforms like LinkedIn to connect with one another, businesses that engage with directly with consumers on platforms’ brand pages, and businesses that place advertisements to reach specific audiences of prospective customers. 

In the debt collection industry, the use of social media is regulated by the Consumer Financial Protection Bureau when used as a channel by which traditional call-to-collect debt collection agencies attempt to reach consumers that they couldn’t reach by phone must comply with the Federal Debt Communication Practices Act (FDCPA) and other state and city consumer protection laws. 

The CFPB’s new debt collection rule addresses appropriate ways to use social media (among many other things), but the rule doesn’t explore the use of social media as a tool beyond private messaging. Social media platforms are very useful tools for digital debt collection agencies and creditors to communicate with consumers but not in the way you might think.

Two things you should not do with social media

Friend request

Sending friend requests to join a consumers’ social network without making it clear that the purpose of your friend request is to collect a debt is a deceptive practice. Businesses attempting to reach a consumer should never attempt to have an agent attempt to secretly infiltrate a personal network in this way.

Instead, if you are going to send a friend request to a consumer, your message should be similar to the Zortman message and make your intent behind the request clear. Beyond that,  and must be a private request (see below on third party disclosure concerns). 

Post on feeds

Posting a debt collection communication on a public-facing account that allows others to see the content of the message on their feed, is an explicit violation of the FDCPA’s prohibition on third-party disclosure. This would publicly expose the existence of that consumer’s debt to anyone who can view the page and is akin to the old (now prohibited) practice of public debtor boards that the FDCPA sought to end.

This doesn’t mean that social media platforms are entirely unusable in the collections space. They can actually prove to be great places to share resources and provide easy access to your team so that consumers can reach you at their discretion.

How social media can help digital debt collection

Directing to support teams

The easiest way to make effective use of social media platforms for your business is to clearly present your company’s website, phone number(s), email address(es), and mailing address(es) online. Increasing visibility and keeping your lines of communication open can lead to greater engagement. 

This is especially important for digital debt collection agencies that make use of payment portals and other online tools as you can guide consumers directly to the answers they’re looking for.

With a public-facing social media account, you will find that consumers will reach out to you with questions—even questions related to their specific accounts. You want to make sure that you are prepared to answer these questions in a discreet but helpful manner so that the consumers get the information they need without any extra disclosures about their debt. 

Consumers expect this ease of access from any business, and it can make an enormous difference in the collections industry that remains largely call-based. Here’s an example of a consumer reaching directly out to our team on Twitter!

The identity of this consumer has been anonymized here, but this is a public-facing post directly on our feed.

Brand Awareness 

Social media platforms offer businesses the opportunity to advertise directly to specific customers based on their online activity. Collections agencies can use social media advertisements to build on brand awareness and help gain customer trust. Providing a hyperlinked statement about your company such as your mission, motto, or BBB rating that will appear in the personal advertising feed is not a collection communication – as long as it does not explicitly address that the consumer is in collections and cannot be shared to their social networks. 

It allows the consumer, if they choose, an easy way to investigate a company’s website, identify your business as legitimate, and gain trust in your brand.

The role of social media in debt collection continues to evolve as legislative bodies more clearly identify how it is currently being used and how those uses overlap with existing legislation. Social media platforms are an omnipresent part of consumers’ lives, and it may seem like an easy way to reach them, but the most important thing to consider is the compliance and security of their information on evolving channels. 

Mastering digital communications is easier when you choose a team at the forefront of the industry. Interested in learning more about digital debt collection? Check-in with our team.

4 reasons companies worry about digital debt collection

By on March 26th, 2020 in Industry Insights

Committing to work with a collections agency can help to reduce the strain of losses on your business. Whether you’re an eCommerce platform with mounting chargebacks, a small lender, or a rapidly growing bank, working with the right collection agency can reshape how you manage delinquent payments. 

Some digital debt collection options also offer self-service products or platforms that allow companies to manage their collections efforts with an internal team supported by powerful, digital tools while other digital companies offer full-service collections.

No matter how you (or your collection agency partner) choose to collect, there are pros and cons to different approaches, and the newness of digital debt collection can create some cause for concern. It’s important to be informed and understand how digital debt collection can help you and actually directly combats many of the risks associated with collections.

“There’s a compliance risk”

Debt collection is a tightly regulated industry and in order to collect debts safely, companies have to conduct extensive training and build processes that adhere to those regulations. This includes federal laws like the Fair Debt Collection Practices Act (FDCPA), the Telephone Consumer Protection Act (TCPA), and any legislation passed through the Consumer Financial Protection Bureau regarding collections practices. Regulations on collections also vary broadly at the state-level. 

With all of these regulations in mind, companies that are beginning their debt collection efforts may be wary of investing in an extensive, internal infrastructure and will instead partner with established third-party debt collection agencies. Several digital debt collection platforms and tools have built-in compliance measures, but they still require internal teams to manage. With the proper systems in place, however, they can be used to great effect as they are coded to align with legal compliance measures. 

TrueAccord’s legal leadership team has been in the industry for decades. You can check out some of our legal advocacy work here and here!

Full-scale digital debt collection agencies take this a step further and are able to provide comprehensive debt collection services with built-compliance software alongside technology experts that manage the product for you. With measurable digital channels taking priority over agent calls, compliance fixes are integrated into every communication, no training required.

“This will impact how we talk to consumers”

Traditional collections agencies are driven by a call-to-collect model of business that leans on agents calling consumers. The collections industry has remained largely unchanged in its practices for decades, but consumer preferences have shifted. It’s becoming increasingly difficult to reach consumers over the phone; in fact, in the State of Collection 2019 report, one industry leader included in the survey said that “right-party contact has fallen off a cliff.” 

Transitioning to digital debt collection from traditional models is easier than you might think. Want to learn more about how easy it can be? Get in touch with us.

In order to meet the growing demand for convenient communication methods, digital debt collection strategies are redefining the industry’s approach to connecting with consumers in debt. While this digital transition will have a lasting impact on the collections industry, companies looking to start or change their collections strategy have the opportunity to work with partners that are embracing the change. 

“Setting up new technology takes time”

Implementing new processes always takes time. Using a traditional call-to-collection agency still requires building a business partnership and sharing debt portfolios for agents to begin working accounts. In the digital debt collection world, implementation can begin quickly and is made easier by uploading CSV files of contact information directly to the online platforms and applications.

Using internal digital tools can also cause delays due to the need for introducing agents and other team members to the system and allocating training time and resources to building infrastructure. Full-service digital-first collections agencies are able to merge the simplicity of starting with a digital strategy with the value of a dedicated team built specifically to manage these new processes. 

“We aren’t ready to bring on a new tool or partner right now”

Timing can be a blocker for any number of company decisions. Collections and recovery may be a year-round function, but teams still see a seasonal ebb and flow in payment rates. Trying to adopt a completely new strategy in the middle of a busy tax season, for example, can feel like a gamble. Or maybe you’re in the middle of a major acquisition or change in leadership and the business’ future is uncertain.

Even in times of change, it’s important to understand that digital collections tools perform better over time than traditional collections agencies. By beginning your digital approach sooner, even with a small subset of accounts, you can begin to compare digital efforts directly to other collections partners.

Comparing digital-first agencies and tools directly to traditional competitors on the market helps to illustrate the power of digital infrastructure on contact rates. The sooner you start, the sooner you can ramp up, and the sooner you can collect. 

Digital debt collection may be new, but that newness only serves to improve existing systems. Companies that depend on traditional collections efforts can see substantial growth in outreach using digital channels, and those that are not yet collecting have more opportunities to get started now than ever before. Future-proof your company’s losses, improve recovery rates, and keep your customers happy all at the same time. 

Connect with our team today to learn more about how digital debt collection is changing the industry for the better.

Multi-armed bandit models and machine learning

By on February 19th, 2020 in Machine Learning

The term “multi-armed bandit” in machine learning comes from a problem in the world of probability theory. In a multi-armed bandit problem, you have a limited amount of resources to spend and must maximize your gains. You can divide those resources across multiple pathways or channels, you do not know the outcome of each path, but you may learn more about which is performing better over time.

The name is drawn from the one-armed bandit—slot machines—and comes from the idea that a gambler will attempt to maximize their gains by either trying different slot machines or staying where they are.

How do multi-armed bandits fit into machine learning?

Applying this hypothetical problem to a machine-learning model involves using an algorithm to process performance data over time and optimize for better gains as it learns what is successful and what is not. 

A commonly used model that follows this type of structure is an A/B/n test or split test where a single variable is isolated and directly compared. While A/B testing can be used for any number of experiments and tests, in a consumer-facing world, it is frequently used to determine the impact and effectiveness of a message.

You can test elements like the content of a message, the timing of its delivery, and any number of other elements in competition with an alternative, measure them, and compare the results. These tests are designed to determine the optimal version of a message, but once that perfect message is crafted and set, you’re stuck with your “perfect” message until you decide to test again.

Email deliverability plays a key role in effective digital communications. Check out our tips for building a scalable email infrastructure.

Anyone that works directly with customers or clients knows that there is no such thing as a perfect, one-size-fits-all solution. Message A, when pitted against Message B may perform better overall, but there is someone in your audience that may still prefer Message B.

Testing different facets of your communication in context with specific subsets of your audience can lead to higher engagement and more dynamic outreach. Figure 1 below outlines how a multi-armed bandit approach can optimize for the right content at the right time for the right audience rather than committing to a single option.

Rather than entirely discarding Message A, the bandit algorithm recognizes that roughly 10% of people still prefer it to other options. Using this more fluid model is also more efficient because you don’t have to wait for a clear winner to emerge, and as you gather more relevant data, they become more potent.

Multi-armed bandits and digital debt collection

Collections continues to expand its digital footprint, and combining more in-depth data tracking with an omni-channel communication strategy, teams can clearly understand what’s working and what isn’t. Adapting a bandit algorithm to machine learning-powered digital debt collection provides endless opportunity to craft a better consumer experience. 

Following from Figure 1, digital collections strategies can determine which messaging is right for which consumer. Sorting this data in context can mean distinguishing groups based on the size or the age of the debt and determining which message is the most appropriate. In a fully connected omni-channel strategy, the bandit can take a step back and determine which channel is the most effective for each account and then determine messaging.

These decisions take time and thousands upon thousands of data points to get “right,” but the wonder of a contextual multi-armed bandit algorithm is that it doesn’t stop learning after making the right choice. It makes the right choice, at the right time, for the right people, and you can reach your consumers the way they want to be reached.

TrueAccord is optimizing how our multi-armed bandit algorithms create the ideal consumer experience. Come learn more about how we collect better!

3 essential digital channels for collections

By on February 13th, 2020 in Industry Insights

The debt collection industry is in the midst of rapid change. With the decline of the effectiveness of phone calls and upcoming legislation from the CFPB that includes limiting call volume, it’s more important than ever that your company’s collections strategy diversifies and introduces a digital, multi-channel approach to communicating with consumers.

Determining what digital channels work the best for your collection strategy isn’t an overnight decision, and using them effectively is another hurdle entirely. When reviewing potential communication channels, you have to consider how you want to use them, how you plan to scale them, and what the investment will be for doing those things properly.

Email

According to the State of Collection 2019, email is the most commonly used digital channel used to communicate with consumers in debt (beating SMS text messaging by 45%). Its frequency of use, however, does not mean that it is necessarily being used effectively. Sending manual emails haphazardly can lead to mixed results at best.

Trying to send emails at the scale required of a dedicated agency, however, is even more difficult, and poor email management can lead to low deliverability rates, poor domain authority (you may end up relegated to spam folders), and can even end up getting your company’s sending domains blacklisted from reaching any of your consumers. Figure 1, below, shows Debt Collector A’s email sending volume.

Figure 1

Sending hundreds of thousands of emails per month can seem like an effective strategy at face value, but when deliverability is taken into consideration, that appearance changes.

Figure 2, below, mirrors the bar graph in Figure 1 and represents the percentage of the emails sent from Debt Collector A that are delivered to an inbox vs. those that are filtered into a spam folder.

Figure 2

A 2019 email client market share study by Litmus shows just how valuable it can be to understand how to work with individual email service providers that all come with their own unique challenges and filters to protect their users. Gmail, for example, maintains 28% of email users, but only 1% of Debt Collector A’s emails are reaching Gmail users.

Cost

Emails can be an effective strategy, but doing so effectively at scale requires extensive infrastructure. That infrastructure includes five major things, including bringing on email experts to work with email service providers, detailed performance tracking, and creating valuable content for your consumers to engage with. Simple email may not cost much, but building a powerful email-driven strategy from the ground up won’t be cheap or easy.

Emails can serve as the foundation of an omni-channel digital strategy, but creating an ecosystem for consumers to engage at their convenience requires more than one tool.

SMS text messaging

Smartphones abound, and when Americans are sending roughly 26 billion text messages every day, it’s easy to see the potential in the texting as a collections communication channel. Millennials spend 3X more time texting than calling or emailing, and they hold an average of $4,712 in consumer debt (not to mention mounting student debt) which makes them prime targets for daunting debt collectors hounding them about a balance. This can be intimidating and turn consumers further away from wanting to work with you.

SMS allows for fast, direct contact with consumers that are on the move, don’t have time for a phone call, and may have breezed past an email or two. By creating a flexible system with multiple touch-points across different channels, you can create an organic system of contacting consumers rather that gives them the power to contact your team when and where they want.

Key uses for SMS:

  1. Payment notifications
    1. Following up with customers to confirm a payment can help to reassure them that their next step toward financial freedom is done and increases transparency between your business and consumers. 
  2. Payment reminders
    1. Even consumers on a payment plan might forget once in a while. A ping with a text message can be just enough of a nudge to remind them to log in and make their scheduled payment.
  3. Providing instant access to their account
    1. By providing a one-click option for a consumer to make their payment, you can make taking the next step easy! Pairing this option with a simple online payment portal gives consumers the opportunity for a full self-service experience.
  4. Tracking your performance
    1. As is the case with other digital channels, tracking your data and performance is easier than ever with texting. You can A/B test messaging and get consistent results for improving engagement.

When you’re considering what to include directly as part of the content of a text message, keep in mind that people expect texts to be short! Length aside, make sure to avoid:

  1. Sensitive information (e.g., account balances, credit card information, etc).
  2. Misleading information
  3. Threatening consumers
  4. Harassing consumers

Text messages have a 209% higher response rate than phone, email, or Facebook, and part of the reason for that is that they are digestible and often feel informal and friendly. On the flip side, misleading, threatening, and harassing texts not only deter engagement and damage your brand, they are also illegal.

Plus, the CFPB’s proposed rules will give consumers the ability to opt out of text messaging, and your texting numbers can still be blocked manually. Be selective with the messages you send and consider the consumer experience.

Getting started with texting using certain software companies can be as cheap as pennies per message. Full-scale agencies like TrueAccord also make use of SMS tools as part of a broader collections strategy alongside other digital tools.

Direct drop voicemail

Direct drop voicemails (also known as ringless voicemail drops) are a unique channel that can help supplement a digital communication strategy but can’t do much on their own. Rather than an agent calling a consumer directly, a voicemail is delivered to the recipient’s inbox without their phone ringing (hence the name).

The consumer still receives a message from a pre-recorded voice that can relay much of the same information that they would have gotten from an agent, but they do not feel the urgent response pressure associated with a phone call. Much like text messages, direct drop voicemails can be used sparingly as a touch point to remind consumers of upcoming payments or ask them to check an email or call an agent back.

From a cost perspective, direct voicemail offerings can range from a few cents to a few tenths of a cent depending on the provider, and many companies will charge based on successful drops rather than a flat charge for the volume sent which can avoid costs incurred for out of date or incorrect phone numbers.

Both direct drop voicemails and text messages are legally classified as phone calls by the TCPA as the law applies to “placing a call or text to a consumer using the consumer’s mobile number.” Be careful with when and how you decide to use either channel in your collections strategy!

As consumer preferences and collections law continue to evolve, we should expect to see rapid growth in both existing digital channels as well as the emergence of others! Effectively integrating these tools into your strategy together can create a much larger impact than any one channel in isolation, and teams that build these systems today will be the future leaders of the industry very soon.