An adequate compliance management system (CMS) is mandated by the CFPB, to have documented policies, procedures and work instructions which are monitored with corrective action. According to the CFPB, an effective CMS will have a board of directors and management oversight and employee training. A necessary cornerstone of this system is a Consumer Complaint Management Program (CCMP) which includes Independent and Internal Compliance audits to ensure all complaints are addressed including complaints received directly from consumers from the CFPB, BBB or state attorney generals.
Concerning the benefits to using a compliance solution, LaDonna Bohling, IFCCE, CCCO, VP Special OPS at Contract Callers, Inc., said, “The biggest benefit in my opinion is all your compliance ‘materials’ can be stored in one central location. This includes policies, procedures, licensing info and vendor auditing. Users access by individual log-ins…and everyone sees the same information… always up to date… no storing fragments of info on various drives which eliminates the worry of information that is not up to date being shared.”
Chris Dunkum, president of First Collection Services said, “Some of the most significant benefits of using a compliance solution include being able to monitor and meet deadlines; track and trend issues by client, by type and by source; and identify unusual issues as they occur in real time.”
“It saves on labor and time when you have to gather documents for audits,” Bohling noted, while Dunkum said the benefit of, “Being able to turn around and provide that information back to a client about their own accounts and data has been an unexpected and value-added service they appreciate.”
Concerning how processing and staffing may optimize the use of a compliance tool, Bohling said, “Most compliance tools have dashboards that will allow you to see complaint data at a glance on which you may perform trend analysis which allows you to mitigate risks by changing processes and workflows.
“Workflows are documented which eliminates guesswork on what to do from front line management. Labor saving processes include online employee testing and the ability to upload client information such as contracts and scopes of work which enables adherence to client requirements.”
Dunkum, said, “There is a lot to be said about automation and digital processes to eliminate the element of human error as much as possible, but there is no substitute for qualified, attentive and knowledgeable staff who care about what they do. Good people optimize even the best process.”
Something Bohling hopes compliance solutions will be able to do in the future is integrate with collection software for more seamless complaint management.
“Typically, complaint logging and tracking can be labor intensive and often there is duplication of efforts – account records are documented in the collection software and then entered in your compliance management tool,” Bohling said. “If the compliance tool interfaced with the software there would only be one entry and documentation of the complaint.”
Dunkum was matter of fact when he said, “Ultimately, any compliance solution is developed to reduce risk (for consumers, clients and agencies) yet still increase productivity and efficiency. However,” he noted, “many compliance solutions are cost-prohibitive.”