To understand why it’s more important than ever to have a well-defined process to pursue payables, we sat down with Stacy Willis, Director of Operations at Account Management Resources (AMR) to ask her what the changes mean for all collectors.
Can you give us a high-level overview of CFPB’s rule on consumer disclosures related to debt collection?
The CFPB’s December 2020 ruling is the biggest development in the accounts receivable management industry in more than 40 years. There are several key areas that will change how AMR will serve our customers. Two of the ways include the way debts must be itemized in reporting, as well as new standards required to prove collectors have consent to text, or email while pursuing collection.
- It is required in the new rule to communicate with the new standard “validation notice.” This means all collectors must now provide a complete itemization of the debt to the consumer in this first notice. The new federal requirements stipulate that information such as time-barred debt (debt beyond the statute of limitations), credit reporting, and delinquency dates must be tracked in more specific ways than in the past. Over the coming weeks we will be working closely with our customers to obtain these time-specific records.
- All debt collectors must comply with the new requirements demonstrating they have consent to collect payment using current day technology such as text messaging, and email. It is critical to honor these safe harbor procedures for consumers, as the ruling raises the bar on what are already complex compliance burdens in consent tracking. Not only will we be working with our software provider on the consent tracking piece but also the required “opt-outs” to both email and text communications.
These are big changes that must be considered immediately. How will AMR fulfill these requirements on behalf of their customers?
In preparation to comply, we partnered with Interactive Data LLC (IDI). We selected IDI based on their superior quality of demographic information. Not only do we anticipate this helping locate new contact information for hard-to-reach consumers, but this will also help us identify bankruptcies and known–deceased records. IDI is a reliable source utilizing dates of birth and Social Security numbers to return such results and will benefit our process and our customers.
How will the new requirements change the timeline for AMR’s customer collections?
We anticipated these changes and have followed experts in the industry to prepare our company policies and procedures for compliance. We have no concerns and do not anticipate any delay in collections.
How can consumers respond to the collector under these new rules?
Consumers can visit the CFPB website at www.consumerfinance.gov. Consumers will also have the ability to communicate with collectors about the debt directly from the validation notice under the new rules.