Rethinking Debt Placement: Four Principles to Drive Compliance

No longer can first-party organizations simply sell or place accounts with a third party without clear account handling visibility. In the US, the Office of the Comptroller of the Currency (OCC) released new guidance, Bulletin 2013-29, calling for wide-ranging third party risk management and oversight. This bulletin comes on the heels of a sweeping consent order between a major US bank and the OCC covering the bank’s collection practices, notably third-party collection activities.