It is mid-July as I write this. There are four months until Regulation F is implemented. (I know some of you may think, "But the extension!" However, the effective date on the CFPB's page remains 11/30, so we're going to stick with that.)
As many are no doubt aware, there are a lot of moving parts, not just with implementation of these new requirements, but management of these new requirements. And what has become clear, moderating webinars, listening in to other webinars, talking with compliance and operations people, and just paying attention is this: If you aren't automating, you are setting yourself up for failure. Generally, mistakes can be mistakes and learning opportunities. For the debt industry, mistakes are actually dollar signs at best.
Here's a fun question for two different audiences:
Owners, CEOs: How many of your processes are automated and regularly audited?
Compliance and Operations: How many of your processes aren't automated and the audit process is, "Well, Terry just does that part and we have no idea how and look, it gets done, we can just never, ever, fire Terry or let Terry leave"?
To the owners, CEOs, compliance managers and operations managers who felt deeply seen by those questions: don't judge yourself. We're in a highly regulated industry with thin margins. That initial outlay for automation can look steep when you have not just one Terry -- but six or seven.
When tasks that are better automated are, instead, the responsibility of employees, the risks may not seem immediately apparent, especially if you have someone capable in charge of that task. Here are five reasons you want to invest in automation:
1) Terry Leaves. Or goes on vacation. Or has a catastrophic event. That can be the first wobble in a spinning top you thought was going to spin forever. In the worst case, Terry was doing things you didn't know Terry was doing, and you only find out once Terry is gone. You now have a gap in your processes.
2) You Can't Replace Terry Once Terry's Gone (We Miss You Already Terry). In situations where an automated process is automated by Terry, a human, and not T.E.R.R.Y., the latest in collection technology, you are more vulnerable than you've ever been. This key task is now going undone.
3) No One Knows What Terry Is Doing/Did/No Longer Does. Again: processes that rely on a human person will stop working when that human person is gone. The other key point: Terry might not even know that Terry's doing something that needs auditing or automation. Terry just thinks, "This is part of my job." Leaving automated tasks unautomated puts your company at risk of non-compliance.
4) The Longer You Wait to Automate What Terry's Been Doing By Hand, the Messier Untangling Those Processes Will Be. Automation isn't as simple as flipping a switch. And the longer Terry tracks what Terry's tracking, and fiddles with what Terry's fiddling, the less sure you can be that you're capturing all the data-points necessary, or even fully understanding what Terry does.
5) You Can't Afford to Not Automate. Automation smoothes out processes, making them reliable, measurable, and dependable. It also allows Terry to focus on things Terry might be better at. (And, of course, this is just life under capitalism: you may find that you don't need Terry. Which can free up resources.)
There is never a good time to switch everything about your current business. It is absolutely going to be disruptive and there will be headaches.
But having said all that: Can you really afford not to?
For an indepth look at the ins and outs of automation, check out Telrock's whitepaper: Automation is Key to Collections Success: What You Need to Know