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Industry Response to the CFPB’s NPRM for Debt Collection

What these newly proposed regulations mean for collections communications

May 9, 2019

Yesterday, the Consumer Financial Protection Bureau (CFPB) hosted a Town Hall Meeting in Philadelphia to discuss their Notice of Proposed Rulemaking for debt collection.

As advocates of trustworthy and transparent communications, Numeracle has a key stake in the resulting outcome of proposed new legislation as it applies to an organization’s continued ability to deliver legal communications via the channel or methodology that is preferred by the consumer.

Observations Across the Group

A number of representatives participating in today’s Debt Collection Town Hall discussion struck on a similar cord, stating that high quality communication between all stakeholder parties is the key to effective debt resolution and positive experience across both sides of the table. Numeracle couldn’t agree more.

Image credit: Consumer Financial Protection Bureau

The collections cycle was born out of a consumer finding themselves in a difficult situation, in need of some form of resolution. Communication, in this case, is the key to getting to that resolution, and the consumer having the opportunity to control their preferred methods of communication is necessary for success.

Privacy vs. Transparency

Chief Executive Officer of insideARM, Stephanie Eidelman, raised an important topic during the Town Hall Meeting as it related to ‘privacy vs. transparency’ in communications. She noted that today’s consumers want to know ‘who is calling’ and ‘why,’ demanding transparency, as much as they’re demanding privacy. But when we consider the collection industry’s use of the voice channel to reach the consumers, as it applies to privacy, the laws of disclosure can unfortunately drive an unintended perception of ‘shadiness’ on the part of the calling party. Without collectors being able to clearly represent themselves, their reputation, along with their ability to communicate effectively and transparently, starts to suffer.

With the introduction of call blocking and labeling analytics into the call delivery ecosystem, this representation and ability to communicate suffers even further.

“Collectors, who are already not operating on a level playing field when it comes to ease of navigating communications regulations, are now seeing their legal calls improperly classified as SCAM, FRAUD, or HIGH-RISK by call blocking and labeling solution providers,” said Rebekah Johnson, Founder & CEO, Numeracle, and IP-NNI Task Force Member.

These negative labels are being attached to the phone numbers of collections agencies, outside of their control, and in many cases, without their knowledge. The ability to block and label calls as a way to ‘warn’ consumers of potential illegal communications is now prohibiting the effective flow of legal communications, which, when a consumer has opted into and prefers this channel, impedes a wanted conversation from being able to take place.

“With the wider adoption of call blocking and labeling technologies resulting from the telecom industry’s push to implement STIR/SHAKEN, some of the CFPB’s proposed rules will be rendered useless before they’re even implemented,” added Johnson.

Ease of Consented Communications

The ability to have a one-on-one conversation with a consumer, live, over the phone is undeniably one of the best ways to resolve problems quickly and effectively. The goal on both sides (including the collector and the debtor) is to reduce the total amount of phone calls needed to resolve. And it’s important to remember that consumers CAN always opt-out of receiving communications via particular channels, and they may exercise their right to do so at any time.

Numeracle will continue to push for enterprises of all industries’ continued use of their consumers’ channels of choice. This is a one-to-one relationship that should be governed by the call originator and the consumer, no one else. When a consumer has consented to receiving calls via the voice channel from a particular organization they have a relationship with, they should be able to do so with ease.

To learn more about Numeracle’s mission to return trust and transparency to voice channel communications across the collections, retail, resort, security and healthcare industries, give us a shout.

©Numeracle 2020
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