blog compliance insights

We last left off with a question on how to avoid UDAAP claims and offer consumer convenience using modern forms of communications.

Sure, receivable obligations might not always mean we get to choose how we are asked to “pay up” but let’s be serious, we all like to control who talks to us and how they talk to us. Everyone wants a modicum of self-dignity, especially when one falls into financial distress. Humans are hardwired to be defensive and unfortunately a phone ringing and the person on the other end of the phone, is becoming more and more like a bad driver who cuts you off.

Perhaps as important, is that we have become a “voice-free” society when it comes to communication. Consumers are less and less likely want to talk on the phone and prefer nonintrusive forms of communication whereby late at night…. they can choose to read and respond at their leisure. Thus, the preferred texts and emails. Texts and emails are how we communicate with our friends and family, doctors, reservations, and reminders. Why not communicate with creditors and receivable managers the same way?

Before the Notice of Proposed Rule Making (“NPRM”) was released on Debt Collection, the industry was unsure if, by using modern forms of communications, that they might be fined, sued, and well, let’s just admit it, no one wants to be the first to fail.

Now, the CFPB has said, “its ok, go ahead…but do it right”.

The solution in an easy recipe:

But simply sending a text or email is not going to work on its own without more thought.

Consumers need an optimized and pleasant experience that allows payments, payment plan, disputes, and an experience which uses an optimization engine to timely and with appropriate volumes makes the journey more ……convenient.

Ingredients:

  • Start with the base: texts or emails.
  • Add – artificial intelligence to assist with the experience, reminding the consumer that they may have journeyed close to paying and stopped, but there are options.
  • Add – some nice follow-up and more interaction and “voila” … data on consumer behavior bubbles up to the surface, allowing more and more targeted experiences!
    • Success!! You have just completed the recipe for consumer convenience thus avoiding unintended Unfair Deceptive and Abusive Acts or Practices (“UDAAPs”).

The Result is the Solution- Remitter’s Ai optimized communication platform*.

*Remitter provides a platform for creditors to communicate with consumers in a manner they prefer- on their cell phone. Remitter has built in guardrails for contact volumes (think- NPRM seven (7) times in 7 days or Massachusetts, two (2) times in seven (7 ) days) and call/text/email times of day using artificial intelligence to continuously optimize and interact with the consumer in their most convenient channel and device of choice.