LAS VEGAS — Speech analytics and call recordings can offer some tremendous opportunities to analyze communications between consumers and debt collectors, especially at the dawn of a new era in debt collection. Looking at the 100 days before the enactment of Regulation F and the 100 days since the rule went into effect on November 30, one debt collector was able to analyze just how much consumers have made reference to Reg F or its provisions, to see how often consumers were bringing it up. Nick Prola, the general counsel at PFC, shared the results of that analysis, as well as the results of a survey of debt collectors undertaken by his agency and several others, to gauge the initial impact of Regulation F on collection activity.
Overall, Prola noted that at his agency, there was an 19% increase in the number of consumers using Reg F-related words and phrases — such as itemization and call frequency — in the 100 days after Regulation F went into effect, compared with the 100 days before it did. Consumers used the words itemization date, itemization amount, or original creditor information only 4.6% more after Regulation F went into effect, Prola noted during his presentation at ACA International’s Ignite Conference.
While many in the industry question whether Regulation F’s Model Validation Notice is making it easier to collect on debts, the survey of collectors revealed that only 6% think the notice is making collections harder. Twenty-seven percent of collectors said it was easier to collect after their employers started using the MVN and 67% said there was no change. The key to this, Prola said, was making those letters viewable to collectors so they could reference them during their communications with consumers.
One-third of collectors noticed an increase in the number of consumers inquiring about how many calls the collector had made to try and reach them, possibly in an attempt to make sure the collector had not violated the call frequency provisions of Regulation F. To help address this, Prola said his agency has decided that all outgoing calls are being made through the same toll-free number, instead of using different phone numbers with different area codes. Using a single number for outgoing calls provides a single, specific point of reference that collectors can make to consumers when asked how many times they were contacted. The collector can ask how many calls were received from that one number to identify calls made by his agency, as opposed to calls that may have come from somewhere else.
