The CMI Group has always been committed to adherence to all applicable industry-related rules and regulations. We have an excellent reputation in that regard. Thanks to our CEO's role as the former ACA President and Board Chairman, we were fortunate to participate in meetings and conversations yielding in-depth knowledge that has allowed us to stay ahead of the curve as the CFPB develops its complaint resolution program and agency audit process. The CMI Group has implemented and continues to develop the most proactive, robust compliance process in the industry.
Our compliance team consists of the Chief Compliance Officer and General Counsel, as well as the ACA-trained Director of Compliance and Quality Assurance. This group bears the prime responsibility for establishing and maintaining the Compliance Management System, described below, and enforcing compliance policies. This team stays abreast of all applicable federal, state, and local laws and regulations and implements any necessary changes to enforce compliance.
As depicted below, there are four central components to our Compliance Management System:
We conduct weekly, monthly, quarterly, and annual audits of those functions that present the greatest risk to consumers. We maintain a monthly report card for areas that are specifically identified by the CFPB as posing the greatest risk to consumers.
Audits are conducted by the Director of Compliance and Quality Assurance. Any irregularities or nonconformities are reported to the CCO and responsible department heads, and follow-up activities are conducted to ensure that any identified issues are corrected.
We conduct an annual external audit to ensure that our practices are consistent with others in our industry and that our policies are being enforced as we intend them to be.
Our policies are drafted by the department owners to ensure they are sufficiently detailed to adequately address areas of concern. Final policy approval comes from our CCO. The Director of Compliance stores final policy revisions and maintains the change log. Annual policy reviews are conducted to ensure our policies cover all areas of concern and that those already in existence are still current and sufficient.
COMPLIANCE MANAGEMENT COMMITTEE
This committee consists of key department representatives who conduct monthly meetings to ensure our policies are current, and that each department is aware of what the other departments are doing. This helps avoid inadvertent compliance issues. Department members also receive updates on compliance and/or regulatory changes and recent audit results.
COMPLAINT RESOLUTION STRATEGY
We have teams reporting directly to the CCO that are charged with the resolution of complaints. Our process is comprised of two parts: the first addresses written complaints and the second addresses complaint phone calls. By keeping the pulse of the consumer experience we are able to locate and address compliance concerns that are unidentified in regular auditing. All complaints are tracked at a high level to identify trends with clients, policies, collections strategies, and so forth.