Crafting a 2025 Vendor Oversight Strategy for Collection Vendors 

As the new year begins, it is a perfect opportunity for collection and recovery managers to evaluate and refine their vendor oversight strategies. In an era of evolving regulations, heightened consumer expectations, and advanced technologies, effective oversight extends beyond mere compliance and security. It is certainly about compliance and security, please do not misunderstand my thoughts, but adding elements of operational excellence will ensure you are driving the right results.  […]

Commission Rate Alone Does Not Make You a Profitable Client 

As an auditor, I’ve had the unique opportunity to observe the dynamics between creditors and collection agencies. What I’ve learned is this: being a good client isn’t just about offering the highest commission rate.  If you want to build strong, mutually beneficial relationships with collection agencies and ensure that your accounts receive the attention they deserve, there are several factors to consider.  How to Be a Better Client  Being a […]

Is a Creditor now a Debt Collector? 

As an employee of a major credit issuer, I led collection teams responsible for recovering debts for the Bank. The Bank maintained that these teams were not classified as debt collectors under the FDCPA. However, our collection strategy adhered to FDCPA guidelines to ensure fair treatment of consumers. At the time, I believed that transitioning to full compliance with the FDCPA, if required, would be relatively straightforward for our organization.  […]

National Repossession Forwarders: Who Holds the Key to Compliance Across 400+ Agents? 

Managing a team of 10 people can feel like herding cats—so imagine the complexity of overseeing more than 400 repossession agents. Ensuring compliance, efficiency, and accountability at this scale requires more than just good intentions. It demands strategic oversight, the right tools, and full collaboration between creditors, national forwarders, and agents. But who ultimately holds the key to compliance? The answer is clear: creditors. While national repossession forwarders play a […]

CFPB Seeks Public Input on Addressing Coerced Debt in Credit Reporting 

The Consumer Financial Protection Bureau (CFPB) is requesting public comments as it prepares a proposed rule to address issues surrounding coerced debt and its impact on credit reporting. The initiative aims to amend certain provisions within Regulation V, which implements the Fair Credit Reporting Act (FCRA), to better protect consumers.  This request, known as an advance notice of proposed rulemaking (ANPR), focuses on updating the definitions of “identity theft” and […]

If You Knew the Outcome of an Onside Kick, Wouldn’t That Make Your Strategy So Much Easier? 

My husband is a life-long Detroit Lions fan, and as season ticket holders, we’ve witnessed our fair share of heartbreak and triumph. At a recent game against the Buffalo Bills, as I watched the strategy and execution unfold on the field, it struck me—being part of an NFL team isn’t so different from auditing collection agencies and repossession forwarders. Think about it:  Creditors are the offense, driving the action and […]

Why a Statistically Valid Sample Isn’t Always Necessary

When auditing collection agencies or repossession forwarders, one common question arises: “Do I need a statistically valid sample?”  The short answer: No. While a statistically valid sample can be useful in some contexts, it’s not always practical or necessary in this heavily regulated industry. Instead, a categorical sampling approach often proves more effective. Here’s why. The Case for Statistical Sampling  A statistically valid sample is typically calculated using tools like […]

CFPB Secures $1.8 Billion Relief Fund Distribution Following Action Against Lexington Law and CreditRepair.com 

The Consumer Financial Protection Bureau (CFPB) has finalized a significant enforcement action against Lexington Law and CreditRepair.com, two of the country’s largest credit repair companies. In August 2023, the CFPB obtained a $2.7 billion judgment against these companies for violating federal consumer protection laws. By December 2024, the CFPB began distributing $1.8 billion to 4.3 million consumers from its victims relief fund, representing the largest distribution in the agency’s history. […]

Beware of the Year-End Goal-Setting Process 

Year-end goal-setting can be a tricky time, especially as a leader of a collections team. As the bank mapped out goals for the upcoming year, objectives like contractual losses or delinquency levels inevitably made their way onto the list for collections leadership. While these goals are undeniably important for the bank’s overall success, I often struggled to fully support them as key performance targets for collection supervisors and managers.  In […]

New York Updates Fair Medical Debt Reporting Act: Key Details 

Governor Kathy Hochul recently approved an important update to New York’s Fair Medical Debt Reporting Act, aimed at resolving ambiguities and strengthening consumer protections. The amendment, signed on November 22, 2024, took effect immediately and applies retroactively to the law’s original implementation date of December 13, 2023.  Refining the Definition of Medical Debt  The amendment, introduced through SB 8373, clarifies the definition of “medical debt” to ensure consistency across state […]