As the Consumer Federal Protection Bureau (CFPB) starts to turn up the heat on lenders, regulatory compliance by your third party vendors is more important than ever. In fact, the CFPB recently issued guidelines to lenders regarding proper vendor management practices.
In order to give our clients complete comfort on this issue, in this rapidly changing environment, we have recently strengthened our industry leading compliance program for skip tracing activity. This enhanced program takes the most comprehensive approach to regulatory compliance in the industry and represents the type of “best practices model” that lenders should seek. Key components include:
- A comprehensive code of conduct that each skip tracer is required to sign every year.
- A detailed training program that every new skip tracer must complete before he/she is allowed to work assignments. Periodic refreshers are also included.
- Scripted voice mail messages that must be followed verbatim.
- Scripted “talk off” guides for both 1st and 3rd party conversations.
- A call recording system that records every call (in the states that allow) and includes built in customized score cards for evaluation.
- Utilization of a third party firm that evaluates/scores 3-4 calls per week per skip tracer.
- Matching of all debtor/co-debtor assignments against a national database of litigious debtors. Those matching are segregated into a special “no phone contact” queue.
- A unique IT and data ordering architecture that allows the skip tracer to run research on multiple parties relating to a case without having any access to social security numbers. Additionally, no skip tracers have direct access to industry databases.
- Separate insurance policy designed specifically to address the risks associated with housing confidential information as most data security breaches are not covered under most general liability policies.
For more information, please contact Michael Levison at 678-702-5101 or email@example.com