The handling of a skip’s file has come a long way since the days of handling manila folders filled with crucial data. Today’s software has a way of conglomerating every odd piece of information into a format that can be used by today’s tracers. Given the current state of regulation today, the future of skip tracing software and its users will have to continue to evolve with the times.
“With the uncertainty of the regulatory landscape, companies will either continue with operations as usual or they will opt for a more innovative approach,” Chad Benson, president of LocateSmarter said. “Either way, make sure your skip tracing vendor works for you and can align with your strategies. It will be increasingly more important for skip tracing vendors to be able to customize their products to meet their clients’ demands.”
The fight to obtain the necessary pieces of the puzzle revealing the location of a skip is important but so is making sure the pieces are valid.
“The ARM industry continues to see increased regulatory oversight in the way we run our businesses (agencies, debt buyers, vendors),” John Schaeffer, CIO and general manager, at IDI said. “From a skip tracing perspective, it’s critical to find skip tracing solutions that provide quality information, not just quantity. The costs of bad data can result in significant monetary and reputational exposure relating to FDCPA and TCPA lawsuits. When vetting your skip trace providers my advice would be to verify that they have the proper security certifications in place (PCI, HIPAA, FISMA, etc.) as well as confirm you are getting the highest quality data available.
“Bad data may subject someone who contacts a bankrupt client [to a lawsuit], and a TCPA problem for calling cell phones or contacting the wrong consumer. Every day there seems to be a new rule.”
While most data is valuable, some may cause trouble when regulation prevents its utility.
“When possible, avoid using regulated FCRA data like credit reports,” Darren Charest, president of US Tracers said. “This class of data requires end users to meet many guidelines with significant penalties in the event of an oversight. There are instances where non-regulated data like proprietary place of employment (POE) can even outpace regulated data without all of the red tape, inquiries to credit reports, etc.”
Skip tracing software is a valuable asset, so is the vendor who supplies it. However, it is imperative that the vendor does not become a liability. Once accounts are handed over they are an extension of the agency in the government’s eyes.
“The most important components of skip tracing today are compliance, security, and performance,” Sheila Gabler, president and COO of VeriFacts said. “It is imperative that applicable regulatory laws are implemented and adhered to. You are ultimately responsible for your vendor. You must be apprised as to the location and work steps of your accounts at every step of the process. Establishing a robust vetting process and performing onsite audits is key. It’s no longer sufficient to just produce a document on paper as to how something is being done … show them! When establishing performance expectations be as clear and open as possible about processes and results.”
Once a vetting process is established, put it to work and take a look at multiple vendors as an agency cannot afford to be saddled with a partner that is not the perfect fit.
“Trying to guess what the newest regulatory change will be for the collections industry is like picking the winning numbers in the lottery,” Adam Schell, director at OneClick-Data said. “I think the best advice may just be, try to avoid getting stuck with any one service or one agreement for your information needs. Try to negotiate short-term agreements or make sure there is a way to terminate the agreement if the vendor is no longer able to provide the same level of service. Then make sure that you have other sources, services, and vendors that can help fill in the gaps in case a certain dataset or vendor is lost.”
The future of skip tracing will likely see more regulation requiring more flexibility from collection professionals. Finding a suitable skip tracing product and corresponding vendor is fundamental for continued existence in this competitive industry.
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