For the past several months we’ve reviewed the life cycle of a typical collection account at CBS. From the moment you send us an account for collection, the rules of engagement with consumers change.
As a third-party collection agency, CBS has some specific federal statutes that don’t necessarily apply to you, the original creditor. For instance, the Fair Debt Collection Practices Act (FDCPA) pertains, by definition, to third-party collectors. Other statutes that may apply to you as the original creditor may also apply to downstream vendors such as CBS. In the healthcare field, accounts will be covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Rental and property management accounts fall under the Montana Landlord-Tenant Act. Any account that we credit report must meet the requirements of the Fair Credit Reporting Act (FCRA) and once reported we have to abide by the Fair and Accurate Credit Transactions Act of 2003, known as “FACTA” or the “Fact Act”. Accounts from financial institutions may have requirements under the Gramm Leach Bliley Act (GLBA). Throw in our own internal policies and regulations and it’s pretty clear there is a lot to absorb. In fact, our company manual encompassing all these items runs over 300 pages! How does an agency the size of CBS appropriately train new employees, provide continuing education for current employees and constantly monitor the regulatory and legal landscape to provide the best possible outcome for us, you and the consumer?
For a small local business, we spend an inordinate amount of time in this area. We’ve formalized a program that documents and outlines the training that every employee receives. It starts immediately upon hire and it never stops. Even those in senior management positions, including the two attorneys on our staff are required to attend ongoing training sessions. For this article however, let’s focus on the folks on the collection floor and support positions.
As you might imagine, given the numerous “acts” listed above, the task is daunting. We begin by having a three-day orientation session with each new employee. Here, they are exposed to all the areas mentioned. Of course, reading and talking about it is one thing, but employing the rules and regulations live is quite another. After the initial training session each new employee sits with more experienced team members, listening in on live calls, observing the intricacies of our compliance system and generally learning how the various laws come to interact with each other under a variety of situations. How long does this mentoring go on? It depends on the person. Some master the basics in a few days, others take considerably longer. Some never do appropriately grasp the basics and wash out.
Once the mentor feels that the employee has achieved a reasonable grasp of the issues, they change seats. Now the mentor is listening in as the new employee feels their way through countless situations. This too can go on for some time. We must have a high level of confidence before we let a new employee begin to work accounts on their own. When that occurs, they begin with the simplest and smallest accounts. The repetitive rote of the various disclosures, while intimidating to nearly all new employees, soon enough become routine. Now a new level of one-on-one training begins as our collection floor manager will begin weekly sessions with each employee, going over a new topic each time while reviewing those that have already been covered. In this manner we are able to bring new folks slowly into the more complicated scenarios.
At the same time, all calls are monitored and recorded. Random samples of calls, data entry, credit reporting and payment posting are checked for accuracy and adherence to polices and regulations. Feedback is made to all employees and there is nothing like listening to your own call to assist one in achieving proper technique and verbiage. Even after the employee succeeds in gaining a certain level of proficiency, continuing education is mandated for all. All collectors meet twice monthly for a “brunch and learn” session and even those who have been with us for years have at least one monthly review session with the floor manager.
Extensive? Yes. Expensive? Absolutely. Necessary? Undoubtedly. Because of this you can feel confident that CBS employees are treating your consumers with dignity and respect, all while doing their utmost to follow all the appropriate rules and regulations and still effectively collect your accounts!