Decisioning data that doesn’t cross the line
The consumer data that guides your talk-off strategies is the lifeline to reduced business risk for both you and your creditor-clients. Yet ironically, that same data exposes you to much greater risk when it is used in ways that do not comply with Fair Credit Reporting Act (FCRA) mandates.
The role of FCRA in third-party collections efforts is widely misunderstood. The truth is, when your agency uses decisioning data for collections efforts — including determining ability to repay, eligibility for repayment plans, recommendations for settlement amounts or locating assets for repayment — you cross the line into FCRA territory and are bound to FCRA regulations. Not only that, the data must come from a provider of FCRA regulated data.
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