$16 Billion And Counting: The Cost of Poorly Managed Compliance Communication

Just about every day comes with another headline about a consumer finance company paying out another settlement, or a new enforcement action, or consent decree. Recently, Toyota Motor Credit reached a $7.6 million settlement with the Massachusetts Attorney General’s Office regarding collection practices.  

Since 2012, CFPB activity has resulted in over $16 billion of consumer relief. The amounts in 2022 increased nearly five times from what was paid in 2021 according to the CFPB.

Throughout the customer lifecycle, from originations, through on-boarding, servicing, payment issues, and in the event an account slides into collections, companies must stay compliant with every customer interaction. Between the activities by the CFPB, FTC, state regulators, and AGs, keeping pace with the evolving regulatory landscape has become increasingly difficult. Unfortunately, knowing what action to take is only part of the solution.

Time to Make a Change – Hurry Up and Don’t Wait

After a legal, compliance or operations staff member knows they need to change a customer communication, too often that it just the start of a journey. Once needed language is identified, for example in a letter to the party responsible for seeing that the change is completed, a several step process begins.  

First, they need to make the request for a change through their development organization or the printer or other party who controls their forms. Then, they supply complete requirements and work through the process to get the change made. 

For many organizations, this process can take six months or more to get the change into production. With each day that passes, more communications that go out to consumers and an auto finance, bank, or credit union, further increasing their exposure.  

A Better Approach to Keeping Letters, Notices and Disclosures Compliant

In order to mitigate regulatory risk and improve operational efficiencies, organizations need solutions that enable business users to make content changes themselves. A robust WYSIWYG content editor designed for a business user that allows them to edit current or create new versions of letter templates is essential if organizations are going to keep pace with regulatory change.  

Business users need to have the ability to make needed changes, obtain necessary approvals and put new versions of letters into production without requiring any IT intervention, waiting on a release window, or having to coordinate with an external printer.

Key Self-Service Content Management Features

Many solutions claim to have interfaces that allow business users to make changes but often are missing key features that safeguard compliance and help companies achieve increased operational efficiency.

When evaluating self-service content management capabilities for the management of letters and other customer communications it is important to evaluate the following:

• Usability – Is the solution intuitive for a non-technical user?  Have you seen the solution demonstrated from beginning to end?
• Roles and Access Rights – Can different users be set up to make or approve content changes
• Versioning, History and Audit Logs – Are user actions and template versions maintained? How easily can you show evidence of compliance?
• Template Consolidation – Does the solution allow for management of state or other needed content variations in a reduced number of templates?
• Content Reusability Across Templates – Can you manage certain language, logos, or other content blocks across multiple templates?
  
  

End to End Self-Service

Increasingly print service providers, packaged software and others are offering solutions that deliver some level of control of existing letter content. These features are available after an initial project utilizing technical resources to integrate systems, map letter source data files and set-up and deploy initial letter templates.  

Consumer finance and other financial services organizations need to ask the print service or solution provider they are working with to demonstrate how a business user can put a new letter into production. The ability to take a source data file, map it, and upload content from existing MS Word documents is becoming increasingly valuable.  

Whether for small batch letters that need to be generated in an on-demand fashion or to put new high-volume batch letters into production, true end to end self-service means the ability to manage data and content from initial set up, through changes, to content and source data until a particular communication is no longer produced but merely archived.

Having an efficient compliance process in place will reduce your organization’s exposure to risks and streamline your internal processes. Not sure where your bottlenecks are? Download our Compliance Communication Production Guide to uncover the pitfalls that could be lurking in your process.