Over 100 pages and 2 press releases have given us insight into the CFPB’s much anticipated plans for regulatory changes within the collection industry. While there are several areas that may be impacted, our responsibility is to make sure that our technology will support and quickly address any proposed changes.
One recommendation in particular is clearly within the scope of a technology solution.
Limit excessive or disruptive communications: Collectors would be limited to six communication attempts per week through any point of contact before they have reached the consumer. In addition, if a consumer wants to stop specific ways collectors are contacting them, for example on a particular phone line, while they are at work, or during certain hours, it would be easier for a consumer to do that. The CFPB is also considering proposing a 30-day waiting period after a consumer has passed away during which collectors would be prohibited from communicating with certain parties, like surviving spouses.
CFPB director Richard Cordray’s prepared remarks on this subject were “The proposal we are considering would also put consumers in control of their communications with collectors. One provision would limit collectors on each account to no more than six attempts per week to contact a consumer they have not previously reached. This cap would cover all contact attempts through various phone numbers, email addresses, or postal addresses, including unanswered calls and voicemails. After the consumer has been contacted initially, a collector then would generally be limited on each account to one actual contact per week and no more than three attempted contacts per week.”
While this could introduce a new wave of gloom and caution, we are excited about these changes. Unlike any of our competitors, we were prepared for this 5 years ago and today have proven systemic solutions that address contact frequency limits. Interestingly, these requirements have nothing to do with using an automated dialer to call a cell phone. These recommendations speak to all methods of communication, including land lines. The great news is, you can do most of this today! What you can not do, we will have for you in a matter of days. We at Quantrax are very proud of our industry knowledge and our growing reputation for anticipating regulatory changes and being prepared for their implementation when they are required.
We will carefully monitor the developments surrounding these announcements, and make sure our clients can safely work within any new compliance guidelines.