Latitude by Genesys - User Group

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  • 1.  Reg-F changes - Questions

    Posted 11-16-2021 17:29
    Edited by Bhavya Balasubramanya 11-18-2021 08:55
    Hello All,

    Below are the questions we have on the Beta -2 version, this is a list of questions from various teams:

    1. Mail return was set on an account where we put in the Validation Notice. It did not reset anything immediately. Is this done by the custodian job?
    2. It is mentioned that when a validation notice is still active, then the account will not report to Credit Bureau, provided it was not already reporting. When is this check happening? Is this done by the custodian too? What is the logic behind it?
    3. Itemization info is very broad in terms of fees vs payments. How are others handling files where there are insurance payments vs patient payments or payments vs reversals as they are not actually fees or is the sign of the number matters here?
    4. Why is it that Validation Given will still work when there is already an existing verbal validation for that debtor. Note we couldn't ultimately save it due to the issue we ran into, but how are we avoiding this situation?
    5. We will still need a list of all the DB updates that was done for Reg F related changes. We are not able to find the DB Object names that were added / changed anywhere.
    6. Release notes mention that validation notice , when it comes to letters, are done on letters having code 'DUN'. Does it mean only the 1st statements should have 'DUN' letter code?
    7. What defines a contact? I’m hearing that there still isn’t clear guidance as to whether it’s an action code or a result code that defines a contact. We need this guidance to properly structure action and result codes.
    8. Linked accounts. I’m understanding that an update to one account (such as a restriction) does not carry to linked accounts. This requires debt collectors to make multiple entries (compounded by multiple entries within each account – see attorney representation as an example.
    9. Time zone management. Regulation F requires debt collectors to calculate time zones according to the consumers zip code and area code – Latitude is only calculating time zone by zip code.
    10. Prohibited times and places. The screen for managing times and places looks good, but the guardrail is simply a warning to the debt collector (that the debt collector can dismiss). This also ties into time zone management as times needs to be properly calculated.
    11. Attorney representation. Adding attorney demographics to the Restrictions field does not restrict communications (it doesn’t automatically and there is no option to select restrict all communications) – best we can tell, debt collectors need to manually add multiple restrictions in the Restrictions tab – there is no restrict all option).
    12. Place of employment. Is there an option to restrict calls to place of employment as a default and then allow debt collectors remove restrictions with a consumer’s consent?
    13. Cease and desist. There is nothing in the Latitude system (like Restrictions) that recognizes cease and desist. Like attorney representation, cease and desist should default to restricting all communications and automatically disposition the related accounts (and links) to cease and desist.
    14. Opt-out. There is no feature in the latitude system that recognizes opt-outs. This is a high risk, material element in Regulation F – there should be opt-out functionality for email addresses and mobile numbers.
    15. Authorized third-parties. There is nothing in Latitudes system to recognize authorized third-parties (and the source of the authorization).
    16. Third-parties for location information. There is type functionality, but there is nothing to capture exhausted third-parties for location information – Regulation F permits contact with third-parties for location information one time.
    17. Email and text communications. Texting is managed out of the phones panel; email is managed out of the restrictions and more info panels. Is there a way to consolidate all consumer contact info into one location with all applicable consents and restrictions? Additionally, consent is managed with a check box that a debt collector can easily add or remove (and then add again) – there is no source or relationship to the consent (how can management validate and/or easily find consent?).
    18. Attempts and communications. See what defines a contact referenced above. It looks like debt collectors need to enter both a note and then – if applicable – a contact in contact made (under restrictions) to properly record and calculate a contact. Like email and text communications, consent is simply a check box that debt collectors can check and uncheck – there is no source or relationship to the consent. It’s not clear that the counter for seven and seven, or one and seven is calculating properly (shouldn’t this be a function of real time action and result codes?)
    19. Credit bureau reporting. Is Latitude’s system properly restricting reporting on mail returns?


    Bhavya Balasubramanya

  • 2.  RE: Reg-F changes - Questions

    Posted 11-22-2021 14:34
    @Ian Winder

    Cris Bjelajac
    Business Owner
    Latitude by Genesys

  • 3.  RE: Reg-F changes - Questions

    Posted 11-22-2021 15:46
    Hi Bhavya, hopefully you got my reply to the email you had sent with the same questions. If not, or if you have follow on items please let me know.

    Ian Winder
    Business Owner - Latitude by Genesys