As a Chief Compliance Officer, call monitoring is a big part of managing the compliance within your organization. It’s your responsibility to determine: Are your collectors compliant with federal and state laws? FDCPA? CFPB? Are they meeting contractual agreements with clients? An effective call monitoring program is essential to your overall compliance.
Call Monitoring Scorecard
One of the ways you should monitor your collector calls is by developing and using a Call Monitoring Scorecard to ensure that your collectors are following the policies and procedures you have set forth in regards to communications with consumers. Developing your own Scorecard isn’t necessarily a “one size fits all” process. There are many components to be considered.
You must first take into consideration your own risk assessment. Utilize a weighted score of components based on the risk level and exposure is the first place to start when developing your own scorecard components. What kind of consumer complaints have you received? What about overall consumer lawsuits? CFPB complaint statistics? What should you be monitoring to ensure that your collectors are using compliant practices when collecting on a debt?
There are many things you should include on your Scorecard to ensure compliance with consumer financial law. We’ve compiled a list of the Top 10 Scorecard Components based on activity we’ve seen to give you some guidance to get started.
Top 10 Scorecard Components
- Call Recording Disclosure
- Proper Identification of the Consumer
- Mini Miranda
- FDCPA Third Party Disclosure
- UDAAP (Tone, Language, Deception)
- Proper Account Updates
- Payments Applied According to Consumer Instructions
- Regulation E (Disclosure & Authorization) as Applicable
- Proper Voicemail Instructions Followed
- Proper Communication Regarding the Consumer Credit Report
Do you need assistance with developing your Compliance Management System to meet CFPB regulatory requirements? Contact us today for details on how KirkpatrickPrice can help.