Debt collectors, like everyone else in financial services, are drowning in regulatory changes. In my last posts I’ve discussed IFRS 9, GDPR and, to a lesser extent, the basket of fun known as PSD2. One of the natural human responses to change is to narrow one’s focus to the necessary task at hand and push everything else away. Just focus on ticking the boxes, and ignore the cries to rethink the way we’re doing business. Sweat what we’ve got and don’t spend any money. That’s what I’m hearing at many collection shops when the conversation turns to optimization or advanced analytics. There’s a cost to this approach, though. Collectors are in danger of leaving money — a lot of money — on the table. The IFRS 9 Bucket Challenge Here’s the first reason: Impairment provisions and losses. This is what I have dubbed the IFRS 9 Bucket Challenge. I wrote... [Read More]
If my last post on GDPR and collections left you feeling mildly depressed, you’re paying attention! Now that we’ve scoped out the difficulties, here are a couple of things you can do to prepare. And preparation, like compliance, is important: GDPR sets out some steep fines for non-compliance, and you don’t want your department — or your vendor — to be the trigger. 1. Create Your Data Inventory GDPR wants you to only use the data that is absolutely necessary. Whether your decisions are based on rules or algorithms, you’re going to have to show what data you are using and how it impacts decisions in collections. As someone executing collection strategies, you want to make sure neither you, your department nor the third parties serving you cause the business to be exposed. You need to make sure you understand where the data you’re using comes from, and prove that... [Read More]
Remember the ice bucket challenge craze? Get ready for the IFRS 9 bucket challenge — it’s even more startling, and nobody’s standing by to give you a warm towel. Like GDPR, IFRS 9 poses major challenges for collectors, just as it does for accountants, IT, risk managers and anyone else in the credit business. So now let’s talk about what you can do. Note: While I’m just talking about IFRS 9 here, you do have to approach it and GDPR in concert, because in some areas they seem to be in conflict. You don’t want to gear up for IFRS 9 and then realize you have to undo some of your strategies or processes to avoid GDPR fines. Build your 30-day plan IFRS 9 says if a customer’s risk deteriorates — including becoming 31 days overdue — they go into Stage 2, and you have to start holding lifetime impairment.... [Read More]
IFRS 9 may just be a new accounting standard, but accountants aren’t the only people scrambling to meet the January 2018 deadline. If you’re involved with consumer debt in any way, this regulation is going to change your world. (Unless, of course, you’re in the US – the name of the game for you will be CECL.) I recently presented a webinar on how IFRS 9 will impact collections, and in this post I’ll share two changes that will have a massive impact on everyone in debt collection, from in-house collectors to DCAs to debt purchasers. At 31 Days, Everything Changes When accounts roll from Stage 1 (low risk) to Stage 2 (impaired risk), it’s a big deal. 31 days is a hard trigger that sends an account from Stage 1 to Stage 2. Impairment for Stage 1 accounts is 12-month expected credit losses. Impairment for Stage 2 and 3 accounts... [Read More]
Collectors in Europe who have been ignoring GDPR because it was risk’s problem, or the CIO’s problem, or the compliance team’s problem should think again. GDPR could well be a four-letter word for collections. You’re probably familiar with the General Data Protection Regulation, Europe’s attempt to create a single, enforceable standard to protect the freedom and rights of EU citizens. But you might not have thought much about it from a collections perspective. I just presented a webinar on GDPR in collections, so I’ve got an hour’s worth of material if you want to listen to it. However, I’ll keep it brief here and just give you 11 takeaways to ponder: 1. It applies from 25 May 2018. You have a year to get comfortable with it. 2. It’s not just about social media data. That’s how it started, but it broadened into an all-encompassing piece of regulation by the time it... [Read More]
Last week I sat down with around 20 executives who manage collections for both lenders and debt collection agencies in the UK, to discuss what’s happening in the industry and how analytics — FICO’s specialty — can help. I will discuss my takeaways from this meeting in a separate post, but first I want to share some of the statements made during this meeting. If you ask me, the diversity of opinions in this group, and the participants’ clear desire to improve collections and customer relationships, show how much the industry is changing. This was not your father’s back-room chat on how to squeeze people for cash. This was a group of highly engaged professionals who understand regulations, customer needs and technology as well as anyone in the lending industry. Here are some quotes that should get anyone in the collections industry thinking. Regulation “The FCA is asking, ‘Are we... [Read More]
Utilities are a special case for collections — they often have a public duty to keep customers switched on that can affect collections performance. That makes the success of Thames Water Utilities Limited, the UK’s largest water and sewerage company, all the more noteworthy. Thames Water has improved collections effectiveness by using FICO collections systems to match each customer with the most appropriate and effective collections actions. Thames Water is also using FICO technology to communicate with overdue customers, enabling them to pay without ever having to speak with a collections agent. In the first seven months of using FICO® Debt Manager and FICO® Risk Intervention Manager, Thames Water has collected £10 million using these services, and has accelerated payments from customers for Thames Water at a lower cost. This is all part of an initiative at Thames Water to transform its management of customer debt. As the CFO of... [Read More]
Setting affordable repayments for a consumer is at the foundation of collections and compliance. Fortunately, assessing affordability is getting easier. These are the headlines from a FICO webinar my colleagues and I just presented on the financially vulnerable and how to assess affordability in a robust, compliant and operationally efficient manner. We covered the key regulatory and market challenges, focusing on FCA and CONC principles-based regulation in the UK, and how to interpret requirements for different types of financial debt at different stages of delinquency. The interactive polls of attendees — all of them UK-based professionals in collections and recovery — reveal three reasons why affordability assessment is so important. 1. The biggest headache for most organizations is demonstrating compliance. Excel spreadsheets and basic forms are not sufficient to meet conduct risk goals. A workflow-based tool (like the FICO® Affordability Calculator) is critical to demonstrating the customer/agent steps and steering the... [Read More]
