Are you preparing for an audit with your client? Leveraging technology can make it easier and this article will show you how.

Where to Store your Documents and other Audit Information

There are many places where you can store your information. It can be as simple as setting up folders on your network, using an application specific to audits, or using some other repository.

At Vertican, we use Confluence by Atlassian. This product is a Wiki that provides a secure place to store documents, while assigning different levels of security to each staff member. It also maintains historical versioning with the ability to create comprehensive documents and then export them as PDFs or Word documents.

There are many other similar services including:

Information about your Firm

The client will ask you to provide information about your firm, e.g., contacts for the audit, administration, accounting, IT, collections, operations. You will also be asked for copies of your policies and procedures, detailed audit questions, such as IT specifics, as well as for various licenses, insurance, and other information.

In an ideal world, every client would ask for the information in the same format, or even keep their audit the same each year, but change seems to be the only constant.

Your tool should be able to easily pick various documents and export them to PDFs.

IT information

You will be asked several security questions about how you keep your clients’ data safe! Remember that security is a collection of layers with each protecting you from breaches. The most common breach will be due to something your own staff does, typically violating an internal policy. You should have strong security training for your in-house staff and provide tests regularly to ensure that they understand and live your security policy.

Your clients will ask for various monitors, scans, and tools to prevent information from leaking out, either intentionally or accidentally.

Be sure to minimize wireless connections to your network. Assume that someone can break into your wireless network despite any protection you might have in place. The same applies to cell phone connections.

Any connection to your system should be encrypted, e.g., wireless, cell, internet, and every wired connection. Ensuring that all your workstations are connected via SMB3 with encryption will ensure encryption in motion. This means that all your workstations and servers must be modern Windows 10 / Windows 2016 Server or higher.

SQL Server and any other data repositories should be configured to require encryption.

Collection-Master should be configured as Client-Server and Secure Data. Using Secure Data will ensure that the actual data is safe. Client-Server uses an

encrypted connection between the Client ,the Listener, and the Server. All these encryption techniques are “encrypted in motion.”

Some drives support encryption at rest on a hardware level. If a firm uses a storage subsystem, the storage device becomes responsible for encrypting the data at rest. Avoid using software to encrypt data at rest.

Workstations

Some of your information will be stored at the physical workstation level. To protect this information, you should implement encryption at the workstation level. If you store information on a laptop and carry it out of the office, the entire laptop should be encrypted.

Anti-Virus / Malware Protection

In the modern world, there are many bad actors trying to gain access to your system. In our industry, you are storing both PII and NPI, and this would be a major win for those bad actors if they gain access to this information. With the internet and remote access, there has been a shift from a time when storing your data on your own server was safest because no one could get to it.

Microsoft’s policy to assume that someone is actively hacking and has access to their system. As security is a matter of layers, each layer protects you. They also retain more than 3,500 cyber professionals continually looking for security problems and addressing them as they are found. Remember that you might be protecting yourself from someone that you know and trust. How many full-time cyber professionals do you have monitoring your own system?

You can host your own equipment in a data center or move your solution to Microsoft Azure or Amazon Web Services (AWS). This is not a requirement, but it is a thought for your long-term security strategy.

Backups

You should always have a minimum of three backups and at least one of the backups should be off-site. Your ability to recover from a disaster (and in a certain amount of time) will depend upon your relationship with your clients. You should also maintain historical backups. Every now and then someone needs to restore a file that is over a year old.

vMedia

vMedia has a very powerful exporter module that will allow you to export your documents in bulk. Occasionally, your client will pick 40 “random claims” and ask you to create an export of these selected documents for their review.

Use vMedia’s Viewing module to query and tag a list of documents and select the export option. Choose the Group & Compress Option if you want to build a single Zip file with all of the selected media. The Spectrum Exporter allows you to be more specific about the format that you want to use for exporting your media.

You can also use the Collection-Master vMedia tab to view individual documents. From there you can save the media to a folder.

This article will be continued in the November vConnect, but for those who can’t wait, click here.

Contributed by Luis Gomez, Chief Strategy Officer

Vertican has been closely following the Consumer Financial Protection Bureau’s (CFPB) Regulation F developments from its inception. The ruling, which raises the bar on how debt collection is practiced, has been left to various levels of interpretation. While our software products already have workflows in place to prevent, regulate, and track the debt collection process, we have been proactively working with both Senders and Receivers to enhance our software so that they remain in compliance for when the rules go into effect on November 30. We spoke with Julia O’Day, Account Executive and CFPB subject matter expert, about Reg F and what clients can expect from our product enhancements.

vConnect: Please give a general overview of what areas of collections Regulation F will impact.

Julia: The rules have been released in two parts. The October 2020 rule, which we are calling “Seven-in-Seven”, pertains to how often a firm can call a consumer. It proscribes more restrictive time zone rules on when a consumer can be called and new “inconvenience” restrictions for when and where the consumer may be called. The December 2020 rule relates to a new “debt itemization” requirement for the initial demand letter, among other things.

vConnect: What programming changes are Vertican developers making to support clients in complying with the Debt Itemization Requirements in the Initial Demand Letter rule?

Julia: This new requirement necessitates firms to provide the consumer with an “itemization date” and the consumer’s balance as of this date in the Initial Demand Letter. The itemization date can be one of five dates: the last payment date; charge off date; statement date; transaction date; or judgment date. It is up to the firms to decide the date they want to use. Then, the firms must specify the amount the consumer has been charged in fees and interest, and the amount that’s been credited for adjustments and payments since that date to tie out to their current balance. The information required for this letter comes directly from the senders; Vertican is programming the ability to import and store this data into its products.

Vertican has released new YGC Pcodes to transmit the information needed for debt itemization in the initial demand letter.

vConnect: Next, let’s talk about the “Seven-in-Seven” rule and other new call restrictions.

Julia: This is the one that’s quite complex. Compliance with this rule means that a debt collector is restricted from calling the same consumer more than seven times within seven consecutive days. Additionally, if a debt collector has a conversation with a person over the phone, the collector is prohibited from calling them again for seven days. If a consumer has multiple debts, whether a call is counted on a single debt or on all of them is determined by which party brought up the debts during the conversation. Also, a consumer can now designate a time or a place that is “inconvenient” that the collector may not call them. For example, a consumer may say that Mondays, Wednesdays, and Fridays from 9:00 AM until noon, the consumer is busy and the collector is not permitted to call, or that the collector may not call the consumer at home. Previously, time-based restrictions were related to the consumer’s time zone; consumers could not create their own set of times when they could not be called.

vConnect: Are there any exceptions to the “Seven-in-Seven” rule?

Julia: Yes, there are. The firm can make more than seven calls if the consumer provides consent directly to the debt collector to place another call within seven days. Also, if the consumer initiates a call during a time or from a place they had previously designated as “inconvenient”, the firm has a one-time “pass” to call the consumer back during that time or at that place to try to reach them. If the firm discovers that the phone number that they have been calling to reach the consumer is incorrect, the number of calls to that phone number no longer count towards the call count.

vConnect: How serious should clients be taking this?

Julia: Non-compliance with the new regulations opens the firms and their senders to significant financial liability. Vertican clients are very astute, they know this is extremely important to their business. Vertican understands these concerns and is devoting significant resources to the project.

vConnect: As Vertican’s Account Executive, what has been your role and involvement in how the company is dealing with the Reg F ruling?

Julia: Vertican’s enhancements to our software are completely Sender driven. I have been proactively working with them to understand their needs and intentions, for example, plans to make changes to placement files. In many cases, there’s additional information that they need to send to the firms for the upcoming, new requirement to be satisfied. But not all Receivers are aware of the changes that Senders are making. So, we are taking those programming requests and including them into the programming schedule.

vConnect: How is Vertican developing the tools needed to help clients comply with the “Seven-in-Seven” rule?

Julia: We polled and conducted meetings with some of our clients; the team and I analyzed the rules and we have come up with a with a set of tools that we think are going to be the best fit for the largest number of clients.

vConnect: Could you give an example?

Julia: Sure, for example, our software already supports ways to restrict calling outside of the valid time for the consumer’s time zone by checking the consumer’s zip code and the area code of the number being called. The rule is expanded in that it’s not just the time zone of the phone number a firm is calling, it’s the time zone of any phone number or any address. That’s because the challenge is that cell phone numbers are portable. So, if I have a number on the east coast, but I move to California, I can keep the same number. As a result, Vertican is enhancing the software to look at the consumer’s zip code, as well as the area codes of all the phone numbers, so that the most restrictive time zones are used.

We’re also building in Call Counting to count the valid phone calls firms are allowed to make: so, seven calls within seven days until you talk to the consumer about the debt. Once the firm talks to the consumer about the debt, they can’t call them for another week, unless the consumer calls the firm back first. So, there are complex rules and we’re building a general set of tools that everybody can use.

vConnect: So, what is the consumer’s role in this and how does that affect the debt collector?

Julia: As I mentioned previously, the consumer can now identify an inconvenient time and/or an inconvenient place to call. Currently there is no place in the software, outside of notes, to track this information. Now that the collector needs to identify this consumer-driven information, we are building tools that will support this compliance on each claim.

vConnect: How does this pertain to individual states and individual clients that have their own call restrictions which may be more restrictive than the federal rules?

Julia: We are building in the ability to configure those rules too. So, when the federal government says you can make seven calls, but New York state, for example, says that you are permitted five, the system will support whatever is the most restrictive.

There are even certain clients that only permit their law firms to make a specific number of outgoing calls. For example, one client restricts to three calls, so we are also taking those into account.

vConnect: How reliable will the enhancements be in ensuring clients remain compliant to the rule?

Julia: What we’re building are tools, nothing is foolproof. One of the things we’re doing is we’re masking phone numbers so that they are not visible in the claim when a call is not permitted due to time constraints or call count. However, if a collector has previously written down a phone number and makes a call when it is prohibited, there’s nothing that we can do about that. So, there’s a lot of education and training, firms need to be responsible for the people who are actually making the phone calls.

vConnect: How can Vertican help get clients get up-to-speed on their respective software enhancements?

Julia: We are very pleased to offer two Mastermind sessions in which I’ll be co-hosting. The October 27 session is with Kurt Sund, Q-LawE Product Owner and Chief Innovation Officer; on November 3, I’ll be with John Currey, Collection-Master Product Owner.

These user training sessions are complimentary, as are all Vertican’s Mastermind sessions, and we encourage all our product users to join us. We will be sharing product specific Regulation F software enhancement and implementation details. Video recordings will also be available for those unable to attend. Keep in mind, however, that by attending the live presentation, clients will have the opportunity to ask questions and even submit them in advance. Registration is now open for both!

October 27 Q-Law/Q-LawE Mastermind session details
November 3 Collection-Master Mastermind session details

vConnect: Can Vertican assist should clients need guidance after the Mastermind training?

Julia: Absolutely. We have training and/or consulting hours that clients can buy from the vPortal.

vConnect: Our clients may have more questions about Reg F, our product software enhancements, and what we’re doing to help them remain in compliance. Where do they turn?

Julia: We are here to help. If clients have any questions, for example about the specific requirements and how we are addressing them, the best way to discuss it is by first emailing their product-specific Client Success team. A team member will be able to either answer the question or determine which questions should be directed to me.

Q-Law/Q-LawE: [email protected] | Collection-Master, vExchange, vMedia, YGC: [email protected]

Julia O’Day, Account Executive

Melissa’s key role is as a Business Systems Analyst. We spoke with her about being an identical, mirror-image twin and her experience on the Jay Leno show.

What is your title and when did you begin working at Vertican?  I am a Business Systems Analyst (BSA). I began working for Vertican in April 2021.

What sort of work did you do before having joined Vertican?  I was the Director of Finance for a debt collections law firm that was a client of Vertican.

What is a typical day at Vertican like for you?  A typical day is answering clients’ questions and helping them with the issues they are having.

What do you like most about working for Vertican?  The people! Everyone has been so nice and willing to share their knowledge with me.

If you could learn anything new, what would it be?  Some things on my learning list are Spanish, the piano, and hang gliding.

What was your very first job and how old were you?  I worked the counter at a deli. I was sixteen.

Word on the street is you were on the Jay Leno show. Tell us about it and how that began.  My twin sister and I were on vacation in Los Angeles with her son and three of our nieces. We were doing a tour of the NBC lot. Someone asked our tour guide to come to the Jay Leno set so we could be in a skit. While waiting to be in the skit we got to watch that night’s musical guest practice. I don’t remember specifically what the skit was about, but I remember Jay had on a white wig and mustache. My sister ended up standing right next to Jay and I was behind him to the side a little. When it aired that night, you can clearly see my sister, however, you only see my shirt. Jay was super nice and allowed everyone to ask him questions after the skit was filmed.

What is something about you that may surprise your colleagues?  I have an identical, mirror-image twin. She is left-handed and I am right-handed. When we face each other, it is supposed to look like we are looking in a mirror. As we have grown older, I don’t think we look that much alike, however, people ask us all the time if we are twins. We usually get asked one to two times a week.

What else do you like to do outside of work?  I like to spend time with my family and pets. I’m usually watching one of my nephews play soccer on most weekends.

Share something exciting you did in the last 12 months.  I moved from Missouri where I have lived my entire life to Dallas, Texas. I have family close by in Forney, Texas, so it made the move a little easier.

Do you have a favorite movie, artist and/or book?

Movie:  I don’t tend to watch movies more than once, however, I will watch Hocus Pocus anytime I see that it is on TV.

TV:  RuPaul’s Drag Race

Musical or Other Artists:  Tupac, Adele, Yebba, Bruno Mars

Book or Author:  Joseph Wambaugh, Hollywood Station. His entire series on the Hollywood police department is really good.

Please share a favorite quote.  “It’s never too late to become what you might have been.” – George Eliot

Stacey’s key role is as a Client Success Team member. This month he tells us about being a father and his favorite sport; football.

What is your title and when did you begin working at Vertican? I am a Client Success Representative and I started with Vertican in October 2020.

What sort of work did you do before having joined Vertican? Before joining Vertican, I was a supervisor for a debt relief program.

What is a typical day at Vertican like for you? A typical day for me will be opening tickets, getting them addressed and answered, then closely monitoring for follow ups, making sure all assigned daily assignments are complete before end of shift.

What do you like most about working for Vertican? The teamwork and Employee appreciation!

If you could learn anything new, what would it be? I’m interested in everything that comes along with coding and would love to learn more about it.

What was your very first job and how old were you? Taking out the trash when I was eight years old.

Word on the street is you are a go getter? Tell us about it and how that began. This began when I was playing football as a kid. I played for Queen of Peace High, and I definitely wasn’t the biggest one out on the field, so I had to prove myself in order to earn playing time!

What is something about you that may surprise your colleagues? I’m a father. I have one son who is 13 years old and plays basketball.

What do you like to do outside of work? Fatherly duties, watching football (go Cowboys!), participating in fantasy football, working out, and searching for new investments.

Do you have a favorite movie, artist and/or book?

Movie: Paid & Full

TV: The Wire

Book or Author: The Spook Who Sat by The Door by Sam Greenlee

Please share a favorite quote. “Reading is fundamental” – Non-attributable