Compliance

Seller, Buyer and Collection Agency Due Diligence

Why:     Through a well vetted, industry leading process, DebtTrader takes the guesswork and the legwork out of the process by preemptively making sure that everyone IN the network adheres to a rigorous set of standards.  The uniformity of our buyer and seller information packets mean that both parties can enter into a sale without needing to waste time and resources with the normal document/data gathering and exchange process.

How:     Consumer protection is at the core of the DebtTrader platform. For this reason, all sellers, buyers and collection agencies must complete our rigorous certification process before being allowed to participate on the DebtTrader platform.  We created our certification program to ensure that the DebtTrader Network consists of companies that are committed to doing business compliantly with a focus on protecting not only the consumer experience, but also the consumer’s personal data.   During the certification process DebtTrader’s dedicated Compliance Team reviews licensing, bonds, certificates of authority, physical and data security provisions, regulatory and legal history, the entire compliance management system and employee training tools.  This process is repeated on an annual basis accompanied by an onsite audit to confirm that these industry best practices are continuing to be followed and that ongoing consumer protection remains at the forefront.

Chain of Title Tracker

Why:     Allows for quick and accurate research into customer complaints or other conflicts that can arise when very large volumes of accounts are bought and sold.  Additionally, shifts in regulatory guidance require all parties in a sale to know the location and status of every consumer.  DebtTrader makes this process virtually effortless which, in turn, further helps to protect our clients and their consumers. 

How:     Every account sold on the DebtTrader platform has a corresponding Chain-Of-Title record tree that tracks an account’s ownership over time. This provides the platform the ability to validate that accounts within a portfolio have not been sold by the seller previously, while allowing the flexibility for more complicated re-sale scenarios. Accounts with ownership discrepancies are removed from the portfolio before it is listed on the DebtTrader platform, thus ensuring that the buyer network only sees what can be purchased.

Reduction of Complaints

Why:     In our experience most consumer complaints stem from a lack of oversight and control during and after the debt sale process.  When oversight and control are lacking confusion abounds and a breeding ground for nefarious actors can be created.  With that said, DebtTrader understands that even highly monitored and controlled environments will experience unhappy customers.  Our goal is to preemptively remove, or block known risks from entering our network, constantly monitor our “sand box” to ensure compliance with DT requirements and established laws and to swiftly identify, validate and remediate any remaining complaints or issues.   

How:     Our certification program and ongoing due diligence and auditing has resulted in increased consumer protection and fewer consumer complaints.  When a complaint does occur, the DebtTrader Complaint Manager is a tool created to assist in researching any concerns.  Our dedicated Compliance Team helps ensure a thorough investigation and remediation process occurs to resolve consumer and / or regulatory concerns.  To remain in the DebtTrader Network our Buyers and Collection Agencies are required to research, resolve and remediate consumer concerns and provide supporting documentation such as: call recordings, copies of all communication with the consumer, system of record account notes and remediation documentation including employee disciplinary records if necessary.  By facilitating a thorough detailed response, DebtTrader has established an environment in which consumer protection continues to play a key role for the life of the account.  

In addition to assisting in resolving the consumer’s concerns, DebtTrader also tracks complaints internally by both Buyer and Collection Agency.  This tracking system allows for 2 additional important events to occur.  (1) DebtTrader is able to present Sellers with the Buyer Compliance Overview (BCO) for each potential Buyer before the Seller selects the Buyer to whom they are going to sell.  The BCO contains an overview of the due diligence material as well as the Buyer’s Complaint Ratio.  This Complaint Ratio is derived from the information gathered by DebtTrader’s Complaint Manager.  To remain DebtTrader certified, Buyers in our Network must not exceed a threshold of 1 complaint per 5,000 consumer accounts purchased.   (2)  DebtTrader is able to constantly monitor the complaint activity in our Network to spot any trends as early as possible.  This allows us to reach out to our Network and remediate any concerns as quickly as possible and continue to guard from harm consumers whose accounts have been sold through our Network.

Third-Party Compliance Oversight

Why: DebtTrader believes in practicing what we preach.  We contract with Coalfire, our third-party auditor to ensure DebtTrader remains compliant with industry standards, leading to confidence that the DebtTrader platform is performing as intended while maintaining security and confidentiality of client consumer records.

How: DebtTrader is compliant with System and Organization Controls II (SOC2) standards for Security, Availability, Confidentiality and Processing Integrity.