Edition 5:
Remediation
Remediation
Epiq experts were asked:
What are the toughest challenges with handling remediation projects and satisfying regulatory compliance?
Solutions and excellence regardless of the scale of the remediation efforts
Becky Tye, Senior Director, Client Services: Remediation is our specialty. For every matter we handle, Epiq focuses on delivering reliable, client-centered solutions for organizations facing regulatory or voluntary remediation, including risk mitigation.
Often a challenge for organizations and banks in handling remediation matters is finding an experienced client services team and having access to scalable infrastructure. These are key to managing complex matters with precision and efficiency. Our remediation teams have both. Beyond our expertise, we have the versatility to seamlessly manage large program-level support for widespread noticing and disbursements, while maintaining the same level of care and concern for smaller projects.
This expertise is important for navigating intricate data and restitution structures, managing sensitive topics such as bankruptcy or beneficiary entitlements, and providing regulatory compliance oversight for remediation or mediation projects, which all have unique challenges.
An external challenge with handling remediation efforts is the approval of regulators. Epiq’s team of remediation experts have worked to ensure Epiq has been thoroughly vetted by major regulators, including the Federal Reserve, U.S. Department of Justice, Office of the Comptroller of the Currency, U.S. Securities and Exchange Commission, Consumer Financial Protection Bureau, Federal Trade Commission, U.S. Department of Housing and Urban Development, and U.S. Department of Agriculture.
Being able to tailor solutions to meet each client’s demanding remediation and mediation goals can be challenging. However, our teams embody a culture of thriving on big challenges and delivering services our clients brag about, which is particularly true for our team of remediation experts.
Clarity and communication are pivotal for effective audit support
Bradley Yonover, Audit Program Manager, Program Management Office: At Epiq, we are often deeply involved with both internal and external audits for our clients involving remediation matters.
The single most important issue when dealing with audits, whether internal or external, is understanding what the auditors are looking for with the particular audit. This is often communicated to Epiq by the client’s audit department or a designated point person, making communication with that person or department paramount to success.
Understanding what is actually being asked and the “why” behind it, helps us deliver what is needed. Often, we have to navigate the challenge of receiving requests that are vague. While sometimes this can be intentional, it usually turns out to be a lack of clarity of a particular procedure or the simple recitation of a question asked by someone completely outside the process, as is appropriate for most audit teams.
Having the ability to openly discuss the inquiry to the extent appropriate, allows us to gain insight into the context, where the question is originating from, who is asking, what else they have asked, and why they are making the inquiry. This allows us to better serve the client by understanding the universe in which our answer is being examined. With the additional insight and clarity, we can better nuance our answers to fit that context, versus simply answering, which can lead to further inquiry or confusion. We strive to answer the question being asked – no more, no less.
Our expertise with handling remediation-related audits is always an asset to the process and a key element to a successful remediation project.
Ensuring regulatory compliance in contact centers
David Shuma, Director, Contact Center: In the high-stakes world of remediation work, regulatory compliance is both a mandate and a differentiator. The volume and sensitivity of these projects demand more than just standard procedures - they require unwavering discipline, rapid scalability, and deep regulatory expertise. This can be challenging, but our contact center meets these demands, with rigorous training, proactive oversight, and specialized quality controls embedded into our processes.
One key obstacle is navigating the constantly changing landscape of regulations, client-specific requirements, and technological demands. These challenges necessitate regular oversight of legal developments and updating policies and procedures.
To ensure compliance with applicable regulations, our contact center agents are trained by our compliance team regarding the California Privacy Rights Act (CCPA), General Data Protection Regulation (GDPR), and U.S. call recording laws. We strictly enforce data handling protocols with no exceptions.
In addition, in many instances, client-required compliance training mandates our contact center agents complete certification and re-certification, which are conducted and tracked by our dedicated training team. This can be especially demanding for remediation projects with large-scale staffing needs within our contact centers to handle the volume of remediation calls.
Ongoing compliance is managed through comprehensive quality control reviews by dedicated resources within our contact center team. This approach enables us to quickly identify trends or areas of concern, ensuring that any errors are promptly reported to the team for immediate feedback and correction.
In today’s complex regulatory environment, compliance is not a one-time effort, but rather a continuous commitment. By maintaining a strong compliance framework, we ensure our clients can successfully navigate even the most complex remediation efforts.
By combining vigilant oversight, rigorous training, and a culture of accountability, our contact center meets and exceeds compliance standards. This approach not only protects our clients and their customers, but reinforces our strength as a trusted partner in delivering secure, compliant, and high-quality service with every interaction.
Meeting regulatory obligations with sensitivity and expertise
Rebecca López, J.D., Program Manager, Client Services: When a financial institution or other entity has a regulatory obligation or opts to voluntarily remediate consumers, the span of time of impact can go back several years, sometimes even decades, which can pose additional complexities when handling a remediation.
A lot can change in a person’s life over a number of years, including major life events such as name changes for marriage or divorce, deceased account holders, and situations where a bankruptcy trustee may share an interest in the funds. When it comes time to remediate these customers, this can often mean the customer will need to provide additional documentation before a payment can be issued.
These are highly sensitive topics and our specialists are extensively trained team members who are experts in guiding individuals through the process of submitting additional documentation. They are adept at how to review the necessary paperwork to ensure the parties owed can claim and receive their funds, and that the review process meets regulatory requirements.
This not only demands our team be knowledgeable about documents such as divorce decrees, bankruptcy filings, and wills or other estate documents, but they must also possess the artful skill of interacting with customers using emotional intelligence, compassion, and empathy. Our specialists maintain an awareness that requesting and discussing these types of documents can be emotional, so they ensure their interactions with customers are respectful and professional.
Epiq excels at maintaining the delicate balance of adhering to regulatory obligations while assisting customers with meeting those requirements in the best way possible.
Turning complex data into regulatory compliance
Mary Heins, Senior Program Manager, Client Services: At Epiq, our remediation teams specialize in ensuring we have the systems in place to handle each remediation matter. Our efforts go from managing data, to generating letters and sending payments, responding to incoming questions from our clients’ customers, and reporting the remediation efforts performed, to support our clients to achieve regulatory compliance.
To meet the challenge of accomplishing all the tasks necessary for successfully handling each remediation project, we work with data, document design, legal, and finance teams within both Epiq and our clients’ organizations.
Handling the data is an important but often challenging aspect of a remediation project. Every organization has different data structures, and regulatory and voluntary remediations often involve handling vast amounts of data from various sources, each with its own unique structure.
Our team excels at transforming and integrating these different data sets into cohesive, compliant formats for all types of remediation efforts. We use top-tier tools to cleanse the data and obtain recent contact details, ensuring the best possible outcomes whether it is a single remediation, re-remediation of existing customers, or ongoing efforts with new customers.
We know it is important to ask: Is the data sufficient to support the mail and email campaigns, and payments, and in some cases, to support agent contact from our correspondence center? What might be missing within the data provided? What within the data looks odd or out of place, or different from what we typically encounter or expect? How should systems be configured to deliver reporting, including the necessary final reports provided at the end of the project?
Because of Epiq’s expertise and the technologies we use, we are able to embrace the challenges and complexities associated with handling each clients’ unique data and successfully execute each remediation program.
End-to-end regulatory and voluntary remediation support
Kelsey Attisha, Esq., M.B.A., Senior Project Manager, Client Services: Navigating the complexities of regulatory compliance is one of the toughest challenges faced by organizations. Our expert project management and operational teams understand that meeting stringent regulatory requirements demands precision, flexibility, and a deep understanding of the remediation process.
At the outset, our project managers consult with clients to understand the full scope of the remediation matter and their enterprise requirements. This ensures compliance with both their organization’s policies and regulator’s requirements. This is a critical step that, if missed, will result in many unforeseen challenges throughout the remediation process.
Another way we avoid future issues when implementing a remediation project is by working closely with our clients for each critical aspect, such as drafting check and letter templates to comply with their brand standards, creating project procedures, writing scripts with answers to FAQs, and setting timelines and deliverables to make sure all mailings occur by the required deadlines.
Epiq’s team of remediation experts understands that making our clients’ customers whole is a critical component of remediation projects. We know that partnering with our clients is one of the best ways to avoid challenges with achieving a successful outcome for the customer and their clients.