Compliance2 min read
What a lender asks a collections partner, and what good answers look like
A BFSI vendor review is not a formality to be survived. It is a reasonable set of questions about what happens to your borrowers and your data, and most of them can be answered from the system or not at all.
Any lender placing a book with a collections partner runs a due diligence process, and any partner worth using has already answered these questions for someone else. The questionnaire varies in length and rarely in substance. It is asking three things: can you do the work, will you do it within the rules, and what happens to the data.
Conduct and people
- Are callers and field officers certified and background verified, and can you evidence current status per person?
- How is calling conduct monitored, and what share of calls is actually reviewed?
- What happens to an agent after a substantiated conduct complaint?
- Are agency staff, if any, held to the same standard, and how do you know?
Contact discipline
- Are calling windows enforced by the system or by instruction?
- How are frequency caps applied, and are they counted across channels?
- How is do-not-contact honoured, and how quickly does it take effect?
- Can you produce every contact attempt for a named borrower over the last year?
Data
- Where does borrower data physically reside?
- How is it separated from other clients data, structurally rather than by a filter?
- Who can access it, how is that logged, and how long are recordings and transcripts kept?
- On exit, what is returned, what is deleted, and how is the deletion evidenced?
What a good answer sounds like
A good answer is demonstrable rather than descriptive. Not we enforce calling windows, but here is a call the system refused to place, and here is where the window is configured. Not access is restricted, but here is the access log for this borrower record for the last six months. Vendor reviews are largely an exercise in distinguishing policies from controls, and the fastest way through one is to answer from the system.
The questions a partner should ask back
Diligence runs both ways. A partner should want to know what data will be shared and under what terms, what the lender expects on conduct, who the escalation contact is, and what happens to accounts on recall. A partner who asks none of those has not thought about the relationship past signature.