Historically, collection agencies have viewed compliance as a reactionary, standalone department. Now, there’s an active shift to view compliance as a proactive process that requires full participation and collaboration across all agency branches. Because of this, a collection agency’s compliance management system is not a product. It’s a mindset.
As Rozanne Andersen, Chief Compliance Officer for Ontario Systems, and Wendy Badger, Vice President of Corporate Compliance and Chief Compliance Officer for ECMC Group, explained at insideARM.com’s most recent webinar “Building the Foundation of a Solid CMS,” while compliance departments and tools should still exist and are factors within a CMS, they can no longer stand on their own. Webinar attendees seemed to agree, and took action.
“We’re a smaller company and have diligently worked on updating and creating our CMS for some time now,” said one Assistant Director of Operations who attended the webinar. “We’ve had a lot of great discussions and have made progress in our journey through compliance.”
As a starting point, the CFPB’s Supervisory and Examination Manual spells out four interdependent control components for a CMS:
- Board and management oversight
- Having a compliance program
- Responding to consumer complaints
- Conducting compliance audits
“If you haven’t figured out who composes your governing body that would be a nice first step to take, to make sure that you know who is seated on your board or who is the president, who is the vice president,” Andersen said. “Are they really active, or are they inactive? If they are inactive, do they choose to step up and embrace the responsibilities that CFPB has assigned to the governing body? That’s a first level decision that you need to make, and you should probably make it soon.”
Learn more about the key operational functions the CFPB looks for in a CMS, and how your whole organization can work towards a larger culture of compliance, with our latest report – To the Point: Compliance Management Systems. Get expert advice on how to identify the right CMS tools on the market today. Use this report as a starting point for developing a scalable CMS, regardless of the size of your collection agency. This is a resource no collection agency should be without!