A year ago, I asked a group of individuals from across the accounts receivable management industry for their predictions for 2022. I thought it would be interesting to go back and see what they predicted. To make it even more interesting, I reached back out to those people and asked them to comment on their predictions. Here is what they said.
Mindy Chumbley, Solverity
What she predicted for 2022: This eternal optimist is confident 2022 will bring more opportunity, reduced uncertainty and renewed energy to the ARM industry. We have shown over the last two years a willingness to innovate, to work alongside colleagues and to find new ways to assist consumers, to serve clients and to emerge with profitable secure companies. I’m excited to see what happens next.
Her comments about her prediction: I did see quite a bit of new opportunity and energy in the ARM industry in 2022. The increases in technology along with more affordable technical options made it possible to compete in new markets. The clarity on the data safeguards rule as well as a pushed out deadline also helped reduce uncertainty. The political climate however remained contentious and ever increasing regulatory demands kept agencies busy in the last year. I continue to be thankful for colleagues and clients who are committed to excellence. We make each other stronger and I saw this even more clearly over the last year.
Jack Brown, Gulf Coast Collection Bureau
What he predicted for 2022: I think 2022 will be a year of opportunities within the ARM industry. With 2021 in the rearview mirror, our preparations for Reg F implementation are completed and we will see the opportunities that it presents. Agencies that are able to adapt to the new framework and technologies will continue to thrive, whereas companies that are unwilling or unable to adapt will have a difficult time staying relevant.
His comments about his prediction: Looking back on my 2022 predictions, I think the idea about adapting to the post-implementation of Reg-F is all about the implementation and adoption of emailing and text messaging. Those who were quicker to jump on those opportunities have seen greater success than those who have waited.
Jeff DiMatteo, American Profit Recovery
What he predicted for 2022: In March of 2020 we thought the sky may be falling. There were many unknowns for the industry and it threw consumers into a new normal. Consumers were stuck home, they could not spend like normal and they found stimulus checks in their mailboxes instead of just bills. What did consumers do? They did the right thing and took care of old debt which contributed to an unexpected boost for many agencies that year. We weren’t sure how long it would last, but it went into 2021 and made the year another good one for most in the industry. Most have seen things normalize in collections, but placements for many are still trying to get back to normal. With lower placements, fewer old accounts to collect on, charting the course with Reg-f and the staffing struggles that continue I think we are in for a challenging year. The great thing about this industry and the leaders in it is that we are resilient, creative and hard working. We are up for the challenges and I look forward to a rewarding 2022.
His comments about his prediction: Well, there is a pendulum in our industry even in “normal” times. When the economy may be struggling consumers have less money, are slower to pay bills and industry placements go up. Higher placements that are harder to collect. When things are booming, placements are down for us but liquidation goes up. It’s something that we deal with , but this was intensified during the COVD years. There was a lot of money floating around, debts were being paid off, but placements went way down. Most of us continued to see placements come back to normal in 2022, but I’m not sure if we were ready to start hearing the word “recession”. Pendulum, normalization, Covid, recession, or all of the above?
Dealing with and even coming out of Covid many companies in general changed their recruiting, hiring and training methods. Although we all struggled through this process, I think in the end it opened us up to new ideas, made us stronger, and will enable us to be better companies to work for in the future.
The Industry was ready for Reg F and I think we showed that. Yeah, there was some fine tuning and tinkering to do in 2022, but the industry showed that we were prepared with little issue and even fewer lawsuits (I know bite my tongue). What we were hoping to see, and did see was that it help guide many more into using more technologies that have become available to our industry.
Cheers to 2023!
Michael Klutho, Bassford Remele
What he predicted for 2022:
No doubt 2022 will be interesting.
Personally, I expect that with ACA Industry Advancement Funding support, our industry will put Hunstein in our rearview mirrors – once a number of those cases are actually litigated on the merits. There are no actual damages and more important the vendor processes utilized are automated and inherent in running any business, including the courts. No one see the data.
Reg F too will sort out during the year. Fortunately, there are several nuggets in the regulation that will benefit collections in 2022. Of particular note is the limited-content message. When used properly, the LCM will allow agencies to generate an increase of inbound calls to then resolve outstanding debts.
And while there has been much consternation about the model notice, Agencies using it will have safe harbor when it comes to disclosing a consumer’s FDCPA rights and other required information. It also provides a hard and fast deadline for disputes and validation requests. That too is a positive for the industry.
One of the goals set by the CFPB in enacting Reg F was to allow for communications in the form and manner preferred by the consumer. That includes texting, emails, web-based, phone calls, etc. The regulation includes safe harbors here as well.
In sum, 2022 will include more robust communications with consumers though much of that communication will be in forms other than telephone calls. Time will tell whether the initial notice (in the form of a model notice) generates more disputes and requests for information though it could also result in more payments. As they say, we shall see.
His comments about his predictions: Predictions are like – [________] – everyone has one (or several)! So, here’s my lookback on what I expected to see in 2022, and how they played out.
- Hunstein was a big win for our industry and is now mostly behind us. More important, there was a significant decrease in federal lawsuits following the Hunstein win. And the possibility that state lawsuits would see an uptick never materialized. In short, ACA Member support on Hunstein through the Industry Advancement Fund really paid off, and will pay dividends for years to come.
- Reg F is now fully ingrained into collections, including its Model Notice. Fortunately, we have seen very few lawsuits based on Reg F and the few challenges directed at the Model Notice typically went nowhere. Personally, I’ve not heard of a single lawsuit based on the Reg F-created Limited Content Message, which means that’s working as intended and with little risk. More agencies are also embracing texting and email communications; again, with no real uptick in suits. Omnichannel communications are a must to remain viable and Reg F provided safe harbors to accomplish them.
- All in all, I am humbly pleased to reflect on my predictions which fortunately appear to have played out as I hoped they would.