Verbal Complaints Against Private Collection Agencies

We notified the Department that FSA was not enforcing a contract requirement that PCAs report verbal complaints from borrowers to FSA. The contracts between PCAs and the Department provide that each PCA will adhere to Department complaint procedures. Those procedures mandate specific actions a PCA must take when it receives a complaint from a borrower, including verbal complaints, such as suspending collection activity on the account. During our site visits at three PCAs—Pioneer Credit Recovery, Performant Financial Corporation, and NCO Financial Systems, Inc.—we learned that none considered verbal complaints to be actual complaints because they believed that they had been able to appease the borrower and defuse the complaint. In addition, we found that no PCAs tracked or reported verbal complaints. As a result, FSA was unaware of the number or severity of verbal complaints filed by borrowers against PCAs and how those complaints were resolved. We recommended that FSA enforce the contract requirement that PCAs report verbal complaints to FSA, and develop a quality assurance program to verify that FSA is receiving all verbal complaints.