March 17, 2020: In response to the COVID-19 state of emergency declared at the federal level, the Receivables Management Association International (RMAI) is issuing the following announcements and guidance to its members:
1) Work from Home – Beginning on March 17th, RMAI staff will be operating remotely from home. Members are encouraged to continue normal communications with RMAI staff who will be available by email and will be actively monitoring and responding to voicemail messages with return calls. Each day, on a rotating basis, one member of the staff will work from the association office.
RMAI encourages its members to allow their employees to work from home to the degree that it conforms with local, state, and federal regulatory constraints that are imposed on the collection of debt. It is important to remind members that are allowing employees to work from home to maintain procedures reasonably adopted to the circumstances and ensures high expectations for the safeguarding of consumer data and privacy.
2) Consumer Collection Activity – RMAI expects its members to have internal discussions concerning appropriate collection strategies and to make adjustments as necessary. When contacting consumers, RMAI encourages its members to actively listen for consumer hardships such as reduced work hours, loss of income, or the loss of employment associated with the current state of emergency and to respond appropriately. When a consumer claims a hardship, consider either not pursuing collections at this time or providing some other form of assistance such as an extended grace period, balance reduction, or the suspension of interest. RMAI certified businesses should document these actions as they may be required to demonstrate program compliance.
3) Certification Audits – RMAI is administratively extending to June 1, 2020 the due date of any RMAI certified audit which is due in March, April, or May. This extension also applies to any previously granted audit extensions that falls within these dates. We are not granting requests for virtual or off-site audits as the onsite component is an important part of the RMAI audit process.
RMAI will continue to provide updates as appropriate as the situation continues to evolve, but also expects RMAI businesses to stay abreast of local, state, and federal updates that may affect your business.
This alert is intended for members of the Receivables Management Association International and is for informational purposes only and is in no way intended to provide legal advice. Members are encouraged to consult with an attorney of their choice for legal advice concerning this matter.