Shortly after the Dodd-Frank Act and CFPB were created our organization made the decision to stay ahead of regulation by tying a collector scorecard to our collector bonus program. The purpose of the scorecard was to incentivize professional and compliant collections while driving performance. Our proprietary scorecard used randomly selected call recordings in the evaluation process. The scorecard consisted of five calls per agent that were a minimum of four minutes long and the consumer had to be willing, unwilling, able or unable to pay. Bankruptcies and disputes were not scored. The four categories we evaluated were opening of the phone call, call progression, obtaining full and complete information and compliance with all debt collection laws as well as our employee code of conduct. The scorecard used a proprietary formula to assign an overall scored percentage encompassing all of the aforementioned subjects. The overall scored percentage on the scorecard would be the percentage of the bonus dollar amount the collector received for that month. For example: if the collectors’ performance earned a $1,000 bonus but they received an 80% on their scorecard they would only earn an $800 bonus check. As I’m sure you could imagine, some collectors did not adapt well to this change. The perception was that the company was trying to take money from them. We experienced some negativity and even lost a few collectors who couldn’t accept this change. Almost eight years later we’re confident we made the right decision to hold collectors accountable for how they collect the debt.
In early 2015 we decided to add speech analytics to our way of doing business. In the beginning we underutilized the product with the basic reports provided. During the fourth quarter of 2016 we were contemplating whether speech analytics was worth the cost. We knew that the product had all of the bells and whistles but if we weren’t taking advantage of them, why continue paying the cost? The only way we could justify keeping speech analytics is if it could replace a full-time employee in our compliance department.
We spoke with our speech analytics vendor, expressed our concerns and advised them that the only way we would continue to use their product was if we could create an automated scorecard that replaced our manual process. They agreed to come onsite and help us build the scorecard we have today. There are nine compliance elements of the scorecard including proper ID of self, consumer, company and client, mini-miranda, two-party consent, FDCPA violations, risk and abusive language and legal action mentions. Now, instead of only scoring five calls per agent we evaluate their full body of work throughout the month.
We spent the next two months testing the scorecard for accuracy. We wanted to ensure that we felt comfortable with the scorecard prior to rolling it out to our collectors and ultimately affecting their income opportunity. Senior management feared rolling this out to our collectors because of how it was received years ago. In order to avoid negativity and turnover we had to explain how the automated scorecard not only benefits our organization but also how it benefited the collectors. Believe it or not, we didn’t have to sell the idea to the collectors because the majority of their scores actually increased. It all makes sense because if the collector failed one call out of five that accounted for 20% of their overall score. With the new automated scorecard one failed call out of two hundred has a much smaller impact on their overall score. We have also created standalone categories for excessive silence, profanity, TCPA risk and after-call work which monitors how long it takes for the agent to go from one call to the next. These reports are sent out to the compliance department daily. If there are any issues the collector is addressed immediately. Within three months of implementing the automated scorecard we were able to reduce our compliance department by one full-time employee.
Now that we’ve successfully completed our compliance scorecard using speech analytics, our focus will shift to collector efficiency. A few of the categories we will add are demanding the balance, offering settlements, payment arrangements, call duration and a seasonal category for tax time talk-offs. Even though speech analytics can be costly and may not be a fit for all organizations, there are ways to offset the cost by incorporating efficiency into your business objectives.
Sam Eidson is the Director of Compliance for Delta Outsource Group, Inc. He also serves on the Board of Directors for the Missouri Collectors Association.
