How to Build a Future-Proof Compliance Management System | Ep. 228

Adam Parks (00:08)

Hello everybody, Adam Parks here with an episode of Receivables Podcast. Today I'm here with Irene Hoheisel with ARM Compliance Business Solutions and we're going to start talking today about how your compliance management system needs to evolve for 2025. Irene, thank you so much for coming on and sharing your insights today. I really do appreciate your time.

Irene Hoheusle (00:31)

Thanks for having me, I really appreciate you inviting me here.

Adam Parks (00:34)

Absolutely. For anyone who has not been as lucky as me to get a little bit of prep time with you and get to know you a little bit through the years, can you tell everyone a little bit about yourself and how you got to the seat that you're in today?

Irene Hoheusle (00:44)

Sure, one thing I love to do is talk, so ask me to say something and you're stuck with me. I am a little different than most people in the industry. I come from the East Coast. I'm a first generation Italian. Both my parents were born Italy and I was raised in Brooklyn, New York.

So I have kind of a little bit of both, which makes me a little different. And then I moved to Kansas. So I've learned the hard way that interrupting is rude. had no idea until I was in my thirties and I moved to Kansas that people don't want you to interrupt what they're saying. They don't want to hear what you want to say until they finish talking. So it was a learning experience, but I think I got it most of the time anyway. But when I moved here almost 30 years ago, that's when I got into the collection industry and I was lucky enough to work for the same agency for

I started out as a collector.

That didn't take very long before I became a supervisor, worked my way up to a vice president. I was in charge of all collections, education. I was the compliance officer for the company. I created and presented seminars for clients, became very involved in ACA. I'm currently one of ACA certified instructors and I'm very proud of that. I've been since 2013. And I also get to serve on ACA committees, which I get to create a lot of the product or at least update and give input on the

educational materials. I've been involved in advocacy with ACA and I feel like what I've done I've always felt like I was pretty good at. Probably because I love the people I work with and because it's also interesting and I got that little New York streak that I don't know I like to be a little bit tell people what to do when it comes to certain things. I am extremely patient with people.

I'm one of those people that it's really hard to get me angry. It takes a lot, but once I get angry, you know it, but it's really hard to get me angry. But when it comes to inanimate objects and unfairness, I do get angry. But my father always taught me you're allowed to get angry. Anger could be good if you use it for good. If you're angry and you change something because if you're angry, that's good. If you're just angry and you yell, then you're not using it correctly. That's it. So I choose not to get angry at people, but...

While I was in the industry, like I said, my main thing was I was vice president of collections and education and then evolved into compliance, which I love. I realized how unfair our industry is treated, how there's so many hardworking people in our industry, so many talented people, so many people that worked so hard to try to be compliant and how the government just puts this black eye on us and makes it sound like, you know, we're the evildoers. We're always the one no matter what. I mean, you hear it, you've heard.

in all different types of things when you hear anything that's a commentary from the CFPB or really anybody, FTC, FCC, AG offices.

Adam Parks (03:24)

OCC,

Irene Hoheusle (03:25)

consumers, it's always,

Adam Parks (03:25)

yeah.

Irene Hoheusle (03:26)

you know, they assume it's negative. They assume that we did something wrong on purpose. They assume that we're planning to make people miserable. And it just makes me sad because it really is the opposite. And that's what made me really like compliance because I finally had a voice. I had something I could say. I like to talk. So I would love to go to events that took me to Washington, DC, and I got to sit with my congressman. I used to, when I was in the agency in Wichita, I used to love visiting the house representatives

at the time and talk to them and tell them because let's face it, all these people that are making educational decisions for us aren't very educated on what we're talking about. So they look at something like, well, that sounds good. That sounds actually really, really intelligent. But since they don't do what we do, they have no idea what it really is. So it's nice when someone like us goes and tells them, OK, well, that may sound good on paper, but this is what it actually happens in real life.

Adam Parks (04:02)

Here's the unintended

consequence. Yeah.

Irene Hoheusle (04:21)

Yeah,

when you, both good and bad, and when you teach them, you get better results. So that's what made me really full of compliance. And I've been doing that ever since. And the last couple of years, I got the pleasure to work with on compliance business solutions. I'm one of their compliance advisors and I work with Sara Woggerman. I get to work with Deborah Ciskey and Denise Taylor. And I have some pretty talented women around me, not only teaching me even more of what I knew,

But giving me the feeling of I'm in my niche, I'm where I belong. I mean, this has been great. It's been wonderful. For those of that don't know, ARM Compliance Business Solutions, Sara Woggerman, you're missing out. You need to find her somewhere and meet her.

Adam Parks (05:01)

So I was gonna say, let's talk a little bit about

what it is that you guys do there. What kind of services are you providing to the debt collection industry?

Irene Hoheusle (05:08)

Basically anything compliance and above. So we can do anything from help you build a compliance program, a compliance management system.

We could help you audit what you already have and tell you what you need. We can help do regular ordinary things like build your policies and procedures, but we could also do training. We do a lot of training on this stuff. So we're not afraid to get our hands dirty and get into the weeds with your staff. Anything from auditing phone calls, listening to them, giving advice, creating forms that they could use to make them better. So we put together training programs on everything that we do. So we go above and beyond just,

this is what you need for training, now do it. We tell you how and we help you with the how and we follow up later with the how and we see if it's working for you and move on to the next thing. We don't just drop your flat, say well this is what you need and you you need to get it done. Come back to us when you get it done and we'll look at it. Now we help you get it done.

Adam Parks (05:59)

The how is such

an important part of the process, right? Because if we're not talking about how we're going to accomplish these things, it's great to be able to provide advice as a consultant. It's another thing to be able to provide actionable steps going forward for someone to be able to not only start to execute on it, but to be able to carry those things into the future. And that leads me to today's conversation. Because at this point, originally, when we started planning this, said, okay, we're gonna talk about where to begin your compliance journey. And as we were talking before, I'm thinking, it really

Irene Hoheusle (06:02)

you

Adam Parks (06:28)

I mean, if you're not already on your compliance journey, you are in the wrong business. So I wanted to focus this a little bit more on the evolution of our compliance management systems. And we all have these tools. We have software systems, tracking logs. We have all of these policies and procedures and all of these different things. And with that in mind,

it becomes a living and breathing thing. And so I think it's mission critical, important that we start to really understand how are we going to evolve our policies and procedures based on the changing times. And there's some things that are happening across our space right now that I need to be included in our policies and procedures and other tools.

So let's talk a little bit about artificial intelligence and machine learning is one of those first things that everybody's starting to dip their toe into, but do we have the appropriate policies and procedures in place to truly be successful with it? What are your thoughts or what have your experiences been across the industry as you've helped people keep their policies and procedures up to date?

Irene Hoheusle (07:12)

So.

Well, I will say the first thing is make sure you have the right person in a position to make decisions on your policies, procedures, compliance management system. Because if you have somebody that believes, OK, I created all this, done, that's a problem. They need to understand, like you said, it is a living, breathing thing, and it's constant.

Hahaha

Irene Hoheusle (07:52)

But if you're a person that's afraid of change, if you're a person that's afraid, okay, this worked really well, now I have to completely change it because something just came up, you know, a different client, a different type of client, you diversified, you have a different rule or regulation. So that's the first thing. And that's always gonna be an ongoing thing. But I wanna say something you shouldn't do right away.

 

Irene Hoheusle (08:15)

It was not the Friday, just past the Friday before that the CFPB put out a announcement that they were going to be rescinding some of the guidelines that they put in place, or basically that their opinions on many things. the first thought is, what? Wait a minute. I just went crazy trying to figure all this stuff out to make the regulation F work and now you're going to rescind something?

Adam Parks (08:27)

Sure.

Irene Hoheusle (08:39)

First of all, calm down. They're not rescinding any of the rules. They're rescinding guidance on, yeah. So they're rescinding what they said, okay, well, you asked me question, this is what you said in regulation F, I'll use that as an example, and explain a little more when they gave a little more opinions and some advice about, well, this is what we basically meant. Those are the things that are being rescinded right now. And they're not even permanently being rescinded. They're just temporarily rescinded while withdrawn while CFPB gets to look at it, decide if it's good, and decide if they're gonna put it

Adam Parks (08:44)

guidance.

Irene Hoheusle (09:09)

place,

change it or delete it altogether. So one of the biggest things going forward this year, don't change what you're doing. Cause there are some people, especially in ops out there that they could, thank God CFPB is going away. And now I could, you know, let's spend the next year figuring out how to get things back to making more money and not have to worry about it. Now, please don't do that. That is one of the biggest things that you shouldn't be touching. I'm one on your list to say, Nope. Those compliance people out there have to have to explain it because this is what we're going to see going forward.

Irene Hoheusle (09:38)

Do you remember when Chopra left? He basically gave all the state AG's instructions on how to continue this work.

Adam Parks (09:45)

Yeah, he empowered them

to start creating a mismatch of rule sets that would be impossible to comply with. Yeah.

Irene Hoheusle (09:51)

Yeah, a hodgepodge of things that we're never going to be

able to comply with everything all across the board doing one thing. We're to have to do 100 different things to comply with 100 different opinions of how this should work across all the states. So.

Irene Hoheusle (10:05)

Compliance right now is more important than ever because this is what we're going to see. Some states already started announcing that they're doing so. We all know New York, that they've been a crazy place for a while now. We all know California has always been coming up with things that you want to like, your eyebrows up like, who thought of that?

Adam Parks (10:11)

Already seeing it. Yeah, 100%.

New York, New York,

the rules in New York City are so complex they actually contradict themselves.

Irene Hoheusle (10:28)

Yes, it's going to become a state that it's going to be impossible to collect and be compliant in if they keep.

Adam Parks (10:32)

But that's their objective is not to be a place

in which debt is collected, they can't outlaw it. So this is their next best move.

Irene Hoheusle (10:40)

If you remember when they first did their rules, the New York rules years ago, I really felt one of the things they were trying to do because they couldn't regulate the creditors was to regulate the creditors through us, telling us what we needed to get from them and when the creditors couldn't give it to us. And that was, in my opinion, way of, hey, well, we can't tell you what to do. Guess what we're going to tell them to do, the people you deal with.

Adam Parks (10:47)

⁓ Yeah, 100%.

That's the challenge of state regulators

is it's sometimes it's sometimes it's like 10, 15 people that are making this vote. It's not like the House of Representatives where there's a wide swath of representation on a national basis. Sometimes it's a lot more focused. And I agree with what you're saying about the CFPB is not going anywhere. I did a session with John Tonetti formerly from the CFPB Mark Naiman and Manny Plasencia from TransUnion. And we talked about literally that it's not going anywhere.

Irene Hoheusle (11:05)

I've never done this job.

Adam Parks (11:25)

So let's not get overly excited and start shifting our whole organizations around as if we're going to be able to have some sort of positive impact on our bottom line because the political pendulum continues to swing and it may have swung in one direction temporarily, but it always swings back again. And what you don't want to do is reinvest all the time, energy, money, and things that you put into complying with those.

Irene Hoheusle (11:39)

Eventually going to go another.

Adam Parks (11:48)

that guidance and rule set and then have to do that over again. Because the only thing worse than having to do some of these ridiculous things is having to do ridiculous things twice.

Irene Hoheusle (11:56)

Well, and here's the thing. Maybe some people won't agree with this, but I do feel this is a true statement. CFPB has annoyed us, but they've also helped us. I was never...

ever a person that wanted to work with bad actors. When there was somebody that was doing the wrong thing, but to be honest with you, there wasn't enough out there to stop them from doing it. So there people that just did. CFPB did help with some of those bad actors, but the problem was they hurt the good actors while stopping the bad actors.

Adam Parks (12:13)

Agreed.

The only problem

I ever had was regulation through enforcement. And so I see that as a pretty big issue. think that they overstepped their bounds pretty significantly. I've had this conversation with a number of folks, both formally and currently with the organization.

Irene Hoheusle (12:31)

Yes.

And some of the decisions they made were basically,

yeah, they hurt people that were doing it right. Yeah. So I don't like that. Yeah. That's a hard one. If you tell me...

Adam Parks (12:46)

the unintended consequences ⁓ medical debt reporting is perfect example

Irene Hoheusle (12:54)

I remember when REG-F was first, when we still had the notice proposed rulemaking out there and they were open for comments and we got to actually sit with some people that were decision makers through ACA that they had separate sessions and they invited some people and I was lucky enough to be one that was invited to sit with these decision makers from the CFPB and when we asked them about their rule that they wanted to create on credit reporting,

about having to have some communication first, because they call it debt parking, that they felt collection agencies, they'll just put it on your credit report until you've, you know, they don't care if you know the debt exists. And I said, so your intention is to make sure you know the debt exists, right? They said, yes. And so then why does it have to be that you have to have some type of communication, a letter or that was sent. I said, why does that happen? You can't put it on. I said, do know how many consumers out there will ever, ever.

respond to a letter or give you a bad address from day one. They know from day one they're not going to pay the bill. So you never get a letter to them. You can call to you blue in the face letters are disconnected, numbers are disconnected, they may never call you back. So I have a person who's a professional debtor who's trying not to ever communicate with me. And once they know, well, you know what, if you don't communicate at least once, you can't go on your credit report. How is that benefiting anybody?

Irene Hoheusle (14:06)

It's not that I said, so if your goal was you want to make sure that the collectors are making attempt, then say that. So they have to send a letter. They have to try to skip trace. They have to try to communicate. And if all these things fail, they could send it to the and they said, no, no, there has to be communication period. That's it. has to be communication. So we tried to talk to them to tell them from our angle, but it doesn't mean they still understand. I still think that it's best to try at least.

Adam Parks (14:13)

It's not always the understanding Irene, I think it's also you know, desire plays

a factor. I think that there was a mission to pull medical debt from credit reports. That was the but that was the underlying objective of the activity. And then they had to find a data set that fed that right because if you use current data now, we also don't want to talk about the unintended consequences of

Irene Hoheusle (14:42)

for years.

Yes.

Adam Parks (14:56)

credit scoring and what kind of risk versus reward probability lending is and the two things that the debt collection industry does is we keep interest rates in check by making funds recoverable and we support the availability of credit because as you can see right now if you look at the public data as it relates to new originations, it's moving more to super prime than sub prime because the sub prime

Irene Hoheusle (14:57)

Right.

For people that can buy.

you

Adam Parks (15:20)

credit availability is already starting to get squeezed. So I think we're going to see more of that over the coming years. So I think from a regulatory standpoint, we need to stay out in front of our policies and procedures in that regard. But what about some of the other things that are starting to come up in the space now? Data security is like the number one issue or the number one fear or concern across all debt collection companies. And we saw that in the 2024 TransUnion Debt Collection Industry Report.

Irene Hoheusle (15:26)

you

Adam Parks (15:47)

Have you started to, or how are organizations starting to monitor for those changes and then apply any new rules and changes to the policies and procedures or the compliance management system that they have in place today?

Irene Hoheusle (15:51)

you

You can't rely on what you've already had and what you've already done. That's no longer going to help you going forward.

You have to think outside the box. You have to be a little more interesting. You have to be open to conversation with your IT staff, with people that are in your industry that have had issues before and learned the hard way. I mean, there's nothing wrong with asking a peer. And if you ever gone to any events that are involved in our, and I'm not just talking AC, I'm talking every event that you have people from our industry that attend, we are a very community of industry. We will communicate with each other and help each other more than any industry I've ever been involved in.

Irene Hoheusle (16:40)

And even if we are competitors, we will, because we realize we're all in the same boat. We all have the same reputation and all of us have to fix it together.

They will not just tell you, this is what we tried, this is what we did, this is what happened, this is how we changed it, but they'll send you things. They'll send you links and documents and put you in touch with their vendors. And I think that's the biggest thing is stop being afraid. Don't think you have to do everything by yourself because AI is here. It's not going anywhere.

Bots are here, they're not going anywhere. Hackers are here, they're not going anywhere. So these are all things that we have to understand. We're vulnerable no matter what.

Irene Hoheusle (17:16)

But it's when you have that, that closed mind attitude, like, you know what, we're doing our best. We're trying hard. We put something together and it works for us. So we're good. That's you can't do that anymore. Going forward, you have to have an open mind because things are constantly evolving and changing. So think the first thing to do is learn to network. And if you are good at networking, start using your, your, your, people that you network with, ask those questions, even if they feel a little tough, even if you feel like, well, they're to think I'm not very compliant. If I'm asking this.

Irene Hoheusle (17:45)

So what? Ask the question anyway. Put yourself out there and get some responses back. I think you'd be shocked to find out there are tools out there that we could use to protect ourselves. Even if they're not 100 % yet, they will be. But sometimes getting it on the bottom floor helps them become better. I remember when we were working with different software.

We didn't like some of the things they did and we told them. And after a while, guess what? In the next updates, they had things that we requested fixed in the updates. How would they have even known if we didn't open up our mouths and tell them? Yeah, so it's the same thing. It's okay to start out with something that's good, but if you want it to be perfect, your involvement is part of that. Your opinion, your problems. I always looked at a problem as an opportunity. When something broke, I have an opportunity to fix it and make it better.

Adam Parks (18:16)

and weren't communicating.

Irene Hoheusle (18:34)

I'd rather find out before it breaks. mean, prevention is definitely more important. And that's why when you speak to other people, you learn how to prevent the things that could happen in your own company that happened to them. My father used to say as well.

Adam Parks (18:37)

Sure.

So in that regard, I think

you also start thinking about from a data security standpoint, ACA conducted the cybersecurity session or the cybersecurity forum this year back in March. So staying out in front of the data security issues, I think that's definitely one way to be doing it. The other thing is from a data privacy standpoint, and you brought up a couple of good points.

Irene Hoheusle (18:54)

Yeah, in the fall, in the spring, yeah.

Adam Parks (19:07)

It's important for us to go through and run those policies. We have to go back and look at, for example, our incident response plan and say, from an incident response standpoint, based on today's threats, what am I actively doing? And is everything updated to all the technology changes and other things, different tools or whatever we've changed over the last year and actively going through and doing that? I've been doing it with my team for years.

Irene Hoheusle (19:17)

this outdated yet.

Adam Parks (19:32)

And anytime that any kind of an incident has come up, we have a very specific response plan. Everybody's trained on the plan. Nobody's learning it in the middle of a response. Like you don't want to learn during the incident. I wish I knew this document existed is the worst thing I can imagine hearing within my own organization. I wish we knew that this plan existed. It's not just about creating. It's about making sure that you're communicating across your organization and everybody knows what to be doing with it.

Irene Hoheusle (19:42)

Yeah, the last thing you want to hear is, I wish they would have told me that. I wish I would have known that. That's the last thing you want to hear.

Thank

Education is important.

And not just educating them, testing them, do they get it? Because I know right now we're not going to see a lot of CFPB things happening, but when the CFPB used to come in and it's going to be AGs going forward, you're going to see a lot of AGs trying to act like... And an AG audit is worse than a CFPB audit. So just so you know, prepare yourself. But...

Adam Parks (20:04)

Yeah, AG's FTC. mean, look, pick your alphabet soup. There's nobody's going to stop.

Irene Hoheusle (20:24)

when they would come in, they would say, you know, what do you do with X? And we would tell them and they would say, good, now prove it. And that was the hardest part was the now prove it. And that's what we learned how to do over these years with CFPB is how to prove it. But if you can't show, yeah, if you can't show the changes in that you're going forward, I mean, you're in trouble. You really are because...

Adam Parks (20:38)

Document log.

Irene Hoheusle (20:47)

I want to know what I used to do. You think a good old saying, history always repeats itself?

Irene Hoheusle (20:51)

I want to know what we did wrong before, because even if it's not the same exact scenario, that's going to teach me what not to do wrong going forward. It's like the 2008 whole mess with the banks, with all the banks and things and how we had a whole industry had a hard time, people getting fired, people not having money, all this other stuff. We learned from that, didn't we? mean, a lot of us were in 2009 did better than we did in 2007 before the crisis even happened, because you learn from it. Others did it. Others had a very hard time.

Irene Hoheusle (21:21)

because they weren't open-minded and I think that when it comes to data security that's probably one of our biggest issues right now is because there's so much out there in the world of technology that the bad guys could use we're never going to be a hundred percent

Irene Hoheusle (21:39)

We're not, there's always going to be some smart guy out there that's going to, yeah, we're never going to be a hundred percent. But if you're not constantly auditing, testing, auditing, testing, changing, auditing, testing, changing, not only your physical attributes, but your policies and procedures on how you do it and learning from them each time, learning from them to be a better next time. Forget about being a hundred percent. You're lucky if you're 40%. Seriously.

Adam Parks (21:40)

Yeah, nobody ever is.

And you know, you

make a lot of good points. I guess the the next thing I would start thinking about here. Like we've talked about the artificial intelligence updates, we've talked about the data security updates. Now, how about vendor management, because the vendor management programs within a debt buyer, for example, or an agency or law firm doesn't really matter. We're responsible for everything that's happening downstream. And if we're responsible for what's happening downstream, and we're updating these policies for ourselves, we need to be concerned with updating our policies and procedures.

and how we're managing our vendors and to make sure we're supposed to treat vendors the same way we treat ourselves and do our policies and procedures reflect that as they've continued to evolve since we first wrote them in 2012, 13, 14 whatever

Irene Hoheusle (22:47)

I

hate to say this about our industry, I'm going to.

If I were to ask a group of 100 people in our industry, how often do you audit your vendors and monitor your vendors? How many documents do you have of copies of the letters they send and the scripts they teach their collectors? Have you ever looked at their training? Have you ever visited them and did an on-site visit? If I ever ask any of those questions, most of them are going to say, I don't know, never, I don't know. If I ask their compliance officers, they'll stumble a little bit, but they'll say, well, we've done it.

Adam Parks (23:18)

Yeah, we went there once. ⁓

Irene Hoheusle (23:18)

We first onboarded them. Yeah, we did

1. And that's the problem because just like we were talking about all the different changes that we have to go through and the agency itself has to go through and hiring compliance people in both in-house and out of house, like on Compliance Business Solution, we could work as your compliance department, but we're not in-house. So you have to have both. You have to have people that are helping you, especially if you're a bigger agency. But yeah, if you're...

Irene Hoheusle (23:44)

And we all do use vendors. And if you're not monitoring them, just as closely as you monitor your own, I mean, you don't have to sit there and listen to every phone call, but you have to make sure that internally they are, they need to be giving you reports to say, okay, we do this. We have staff that not just call analytics, because that's also great. I love call analytics, but we also have people that listen to the calls that make sure the notes match the call. Call analytics doesn't do that.

Irene Hoheusle (24:11)

evaluates the call for efficiency, not just to just say the right word, but what could you have said that was better? Call analytics doesn't do that. Yeah, you can't just say we have call analytics, we're good. ⁓ And I'm just giving that one example. Now let's times that by all the thousands of policies and procedures we have to deal with. But if they can't prove to you they're doing that, find a vendor that can because they're out there.

Adam Parks (24:15)

Yeah. Coaching beyond just the compliance piece and and then having the live people for your exceptions.

Irene Hoheusle (24:33)

because vendors know they have to have that type of close relationship with you. And if they're giving you a hard time, especially if someone, used to love when someone would say to me, well, no one else asked me to give them that. I would say, well, know, poo poo on them. Come on.

Adam Parks (24:47)

Yeah, that's definitely not an excuse that nobody else is asking for it. You know, so we've talked away through a few

of the different key areas here. One of the other ones that I know is kind of in a constantly evolving space, and Sara did a webinar recently with Katalina Dawson on my team talking about complaints and disputes and dispute handling. And so how are you watching that both within your own organization and as it relates to your third party vendors?

and making sure that your policies and procedures are up to date for those changes.

Irene Hoheusle (25:21)

well first I'll say disputes and complaints should be your number one thing that you're, if you haven't started the compliance management system, that there should be a number one, start there. How do you handle disputes and complaints? What do you do with them? What's your policies, procedures? Have written policies, procedures, not just this is what we do because I said so. It's gotta be, people are trained on it and they know what to do and you're keeping logs and you're documenting and you've got everything written down. But.

Irene Hoheusle (25:44)

when it comes to your vendors, go back to that same thing. How do you know what they're doing? And the only way to know what they're doing is to have also a policy for that. You have to have a policy about this is how often we're going to be checking with our vendors. This is what we're going to be looking for. This is the documents and the expectations we expect them to give back to us. This is how often we want it. This is the information we want in our reports.

Irene Hoheusle (26:06)

And then every once in a while, do a little surprise. And I'm not saying you have to spend the money and fly out to see them, but do a surprise, make a phone call and say, okay, I need you to send me 10 accounts. I want to see the notes of everything you've done in the 10 accounts from this date to this date, a hundred accounts, whatever. And then you do a little evaluation of what they're doing. You don't have to do it all the time, but you need to do it on a regular basis. And those surprise things, you're going to find more information out from them, especially watch the speed of what they do it. If they get it to you right.

Irene Hoheusle (26:36)

away then you know that they're not cherry picking. If they take a minute it's like why just give me I need it in the next five minutes I need you to send me the the script of the last ten accounts that you just had phone calls in. I need access to listen to these ten phone calls whatever it is but demand it right away and you would be very surprised to see

Irene Hoheusle (26:55)

Are they doing what they say they're doing? Are their collectors saying the things that we expect them to say? Are they actually breaking some of our policies and procedures of what they're doing? And I'm not saying, okay, you're fired, but that is the opportunity for you to train them to do better, to make them, okay, I don't care what you do for your other clients, this is what I need you to do for us. If you're not capable of doing it, let's have a conversation of whether or not this is a good fit. But.

Irene Hoheusle (27:17)

You're not going to find that out if you just onboarded them, got copies of their letters they send, got copies of some of the training they do in scripts and okay, well, you know what? They're pretty good. I'm happy. I'm good with this. And then two years up the road, a policy is not followed and you find out through a lawsuit and then you're, what are you going to do? Ask them, well, you told me that you do this. That's not going to fly. You have to show if nothing else. Well, we just reviewed you three months ago and this wasn't

Irene Hoheusle (27:47)

happening, what went on? They can come back with, well this was a brand new person, it was a one-off thing, it was... but if you didn't do that, have no beliefs. Yeah.

Adam Parks (27:53)

But at least you're facilitating a discussion at that point.

Irene Hoheusle (27:56)

You have no voice. If you didn't do that, you have no voice. What if you're using this vendor for the last five years and all you have is what you for the last 10 years? We've used vendors for, especially when you forward accounts, if you forward accounts to other agencies, now they're doing everything. They're not just doing some things for you, they're doing everything. That needs to be closely monitored. And you should have staff in place that knows this and is prepared to do it with policies that say what they're supposed to do. And that all needs to be shared with every vendor and that vendor needs to sign off on it and agree to it. So you have power.

later on if you find an issue. I don't know why people don't do that and I know a lot of agencies don't.

Adam Parks (28:31)

think that's some really great advice for how organizations can stay up to date on what they need to be monitoring where they need to be looking within their own organization, and how to get an accurate result to the test that you want to run from a compliance perspective for your third party vendors and even internally, because I would take that same methodology that we're applying to the third party vendors and do the same thing internally when you're selecting those account samples.

Irene Hoheusle (28:52)

yeah.

Adam Parks (28:57)

ensuring that as a top level executive, you're not being fed bullshit, and you're getting right an accurate depiction of a cross section of accounts. It's it makes a lot of sense when you say it that way the the cherry picking

Irene Hoheusle (29:05)

Be cherry picking on me.

I don't mind if you cherry

pick an account that this is more likely to pay, so I'm going to work that first. That kind of cherry picking is fine.

Adam Parks (29:16)

That's different. Well, look, that's prioritization of account efforts

and resource allocation. That's a different animal altogether. But Irene, I really do appreciate you coming on and sharing your insights with me today. This was a lot of fun.

Irene Hoheusle (29:23)

Yep.

thank you. It's always fun talking to you, Adam. I appreciate you having me and hope you have me back.

Adam Parks (29:32)

I really do appreciate it. For those of you that are watching, if you have additional questions you'd like to ask Irene or myself, you can leave those in the comments on LinkedIn and YouTube and we'll be responding to those. Or if you have additional topics you'd like to see us discuss, you can leave those in the comments below as well. And I bet you I can get Irene back at least one more time to help me continue to create great content for a great industry. But until next time, Irene, I really appreciate all your insights. Thank you so much. And thank you everybody for watching. We'll see you all again soon. Bye everyone.

Irene Hoheusle (29:54)

Thanks, Adam.