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1.5.5 Collection Analytics

Debt buyers and debt collectors regularly gather data about consumers and also about their own internal collection practices. Increasingly, they use analytics software to evaluate this data and make decisions based on their evaluation.

Services exist to help debt buyers make decisions regarding which debt portfolios to purchase432 and provide real time portfolio monitoring that notifies collectors when specific information changes.433 Portfolio analytics may also be used to score particular accounts so that debt collectors can target their collection efforts to the accounts that they believe are most likely to pay434 or select specific demographics for particular collection techniques.435 For consumer advocates, the use of analytics raise questions about privacy, disparate treatment based on demographic data like race or gender, and the potential for unauthorized use of credit report data.

Companies provide products that will “scrub” portfolios for certain types of accounts including: “bankruptcy, deceased, possible military indicator, cell phone, fraud, [and] litigious debtor.”436 Identified accounts may be marked for special treatment or excluded from collection.

Analytics can be used to personalize the content or tone of a collection communication, the mode of communication (phone call, letter, email, etc.), or even the specific debt collector assigned to contact that consumer.437 Systems may also be able to learn from your engagement with prior communications (e.g., did you click on the link in that email or sign up for a payment plan with a particular collector) in order to tailor future messages.438

Collectors can also use analytic software to record and evaluate collection calls. Speech analysis may either be conducted while the call is ongoing or performed on a recording after the fact.439 Here is one company’s description of its real-time speech analytics product:

EurekaLive: CallMiner’s real-time solution, using the same analytical technology to provide QA and alerts in real-time to supervisors and agents, monitoring in-progress calls for the presence or absence of specific language or acoustic characteristics such as escalation attempts, churn language, profanity, compliance scripts, or high emotion. EurekaLive Agent Assistant monitors every live call in real time (within 3–10 seconds), offering script compliance monitoring, emotion detection, next-best-action guidance, event alerting, and automated context-driven workflow initiation directly to agents.440

Debt collectors using speech analytics may have the ability to issue reports about individual agents that contain data such as the frequency with which they failed to provide required information, deviated from the script, or used prohibited terms.441 Speech analytics software that transcribes recordings may be searchable for particular keywords.442

In the CFPB’s survey of third-party collection agencies, seventeen out of fifty-eight respondents used speech analytics.443 The smallest collection agency that reported using speech analytics had eighty-three employees.444