There is any number of reasons for the current focus on compliance including: litigation/court rulings, client expectations and CFPB supervision. ARM experts and industry leaders are pretty much in agreement that CFBP supervision will affect everyone in our industry whether your company comes under direct supervision or not. It has been cited as potentially having the largest impact on our industry since the passage of the FDCPA in the 1970’s.
One of the many compliance areas that this would be a good time to look at is scripting. Yes, you have scripting, training, coaching and quality monitoring but are all of these areas working together so that consistently compliant calls are being made. Here are some things to consider when doing a compliance review of that scripting:
1. Establish what compliant scripting is – what disclosure and verification steps should be completed on the first contact as well all subsequent contacts and in what order should disclosures and verifications be given in. You may also have different scripting to review if you have clients requirements to address. Some differences that may require managing multiple scripts are things like: do you ask for the consumers address and last four of social security number or do you provide it and ask for confirmation. ARM companies and clients vary regarding which approach should be used.
2. Compare the scripting that your Executive Committee/ CCO have approved to what is trained to what QA monitors to what operations coaches on the floor. You may find significant differences between these areas. Verbal understanding and expectations as well as documentation should be compared for discrepancies. Part of this confirmation process should be not just what is trained but what the expectations are when QA, operations and training are listening to calls or call recordings. Consider what is being scored as a passing call. For example, how is your QA area or operations management scoring calls where the disclosures are given but not until a later point in the call or out of the order the scripting requires. Are you coaching agents not only when a script step is missed but also if steps are completed out of order?
3. Put a trend and root cause analysis process in place to identify and resolve scripting deviations. Understanding how many of the calls being made on a day to day basis meets all compliance requirements is critical to reaching your compliance goals.
Through this review you want to confirm a “culture of compliance” – policies, procedures and practices.