Credit Collections and Risk

In Focus Consumer Credit

Left-right: Darren Guest; Denise Crossley; Hope Bodle; Ian Warne

What do you see as omni-channel – what does this actually mean to you and your business? How would you plan to adopt this approach and what are the key considerations? SC: It is very much a question of 24/7, 365 days a year service providing customers the ability to interact with you as a business given you are a business which they have not chosen for themselves. It is about giving your customers the

empowerment to deal with an organisation quickly and efficiently at an appropriate time and via a platform which works for them. From a collections perspective, it can

be slightly more challenging though as in the majority of cases, first contact is still primarily person-to-person so more traditional means of letter, dial and SMS still drive the fast majority of contact within collections call centres today. You also have very different requirements

at a client level when coming up between the different regulators and clients risk appetites so this too has a large part to play on what can or cannot be done. So there are a lot of challenges and I

do not think that anyone has completely cracked it in terms of an approach, I think that it is still in its early days from a collections perspective so it will be interesting to see how the market takes advantage of the digital technological opportunities coming to the market and whether businesses decide to build their own platforms, work with trusted advisors or is it a hybrid approach?

PM:We have opened up a multitude of different channels like e-mail, SMS, and live-chat, to measure the effect that they

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So there are a lot of challenges and I do not think that anyone has completely cracked it in terms of an approach, I think that it is still in its early days from a collections perspective so it will be interesting to see how the market takes advantage of the digital technological opportunities coming to the market and whether businesses decide to build their own platforms, work with trusted advisors or is it a hybrid approach?

have on both an individual and cumulative basis. Getting the communications audit trail all

into one place is a big hurdle to overcome and you need to have the courage to test and learn, switching channels on and off. For example, we were very big on e-mail

at one point, but we found that it was not conversational enough for some customers, so we have tried to replace that with things like WhatsApp which have proved to be really popular.

SA: One challenging issue is around the use of URL links embedded into messages. Many clients are actively advising customers not to click on links due to fraud and scamming risks so some of the technological advances that companies like Esendex are working

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on such as the use of secure PDF letters embedded into messages require a URL. There are other instances where the

technology has not yet caught up with the client and regulatory position enabling businesses to offer solutions that work from a collections perspective.

DC:We are never going to get absolute clarity from the regulator, they just will not give it. Each business must interpret the rules, however if you drift down the wrong road with good cause and evidence as to your thought process, then they will tell you, but they will not help you to determine initial actions. We are never going to change that

position and, listening to the discussion, it appears to be the same old problem with some of the larger banks whose compliance departments can often be mis-aligned. They may tell you to do something, which actually goes against what your business is trying to do from a compliance point of view of the regulator. But, in general, I agree: you have to offer

all channels, and if the customer chooses a channel, then you should ensure that your systems adhere to that channel of choice when communicating with the customer, to avoid falling foul of the regulatory rules. So going back to the question of contact

and self-serve, I would say that both of those things are important. If a customer says ‘I want to deal with

you via e-mail and e-mail only’, then you have to make sure your systems can accommodate that request, and stop your agents and system from choosing a different channel. Of course, sometimes you may have to deviate from that, because, if a customer

March 2020

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