It seems to me that clients—whether original creditor, debt buyer or otherwise—always like to schedule audits in waves and at the same time! Once one client’s audit notice rolls in, another is sure to follow! Invariably, the audits are, at the same time, both incredibly similar and dissimilar. Similar enough that I am to remember where certain documents are saved (e.g., insurance policies, attorney bar cards, etc.), yet different enough that copying and pasting answers will not cut it. (See what I did there?) So how do I and how can you survive audit season?
The first thing I try (note “try”) to do is to not get annoyed. Yes, sometimes clients have odd-ball demands that seem to make little to no sense. However, in this new era of greater and tighter regulation, I remind myself that while the demands are coming from the client, most likely the demands did not originate with the client. The client might need to prove something to a regulator, or it might be something that they do not have direct control over (like filing lawsuits), and thus the requirement trickles down to the law firm.
Too Little or Too much?
Once my mind is in the right place (and I have refreshed my stock of M&Ms), I make sure I understand what the client is asking. One of the best lessons I learned in Trial Advocacy in law school was “only answer the question that is being asked.” This is especially true of audits: give clients too little and they want more explanation; but give clients too much, and you may have opened the door to them finding something wrong in an area they were not even looking at previously.
After reading through the audit and accompanying deliverables request, if I have any questions, I ask them. Remember, you want to give clients what they looking for. If something is unclear, conflicting or duplicated, point it out to them. Not only will you save yourself time and frustration, but perhaps the auditor did not realize the wording was poor, or that they requested the same information twice but in two different audit sections. Several times auditors have thanked me for pointing out those types of errors to them. Plus, you have made yourself look good to clients by showing them you have spent the time to read and understand what they want – and let’s be honest, it is always nice to look good to the client!
Create Time Savers
Now, let’s get that audit completed! Chances are Client A is going to ask for some of the same information as Client B. If you take the time to create your own audit checklist and folder of important documents, you will save yourself some time. For instance, always know where the insurance policies are kept, and that they are up-to-date. The same thing applies to attorney bar cards. If you keep that information in the same spot on your computer, it is easy to copy and paste those documents to the audit folder. Reference the document in the answer, and much of the work is done. (You will want to pay particular attention to each audit’s naming convention, and make sure you are properly naming documents.) Likewise, create either a Word document or Excel spreadsheet with commonly asked questions and their answers. When completing audits, you can then use this as a quick reference guide for yourself, rather than searching through multiple past audits or asking the IT Director the same question every three months.
Compare with Past Audits
Despite the tediousness of audits, if you know this client audits you every so often (yearly, semi-annually, quarterly), you should have copies of past audits and your answers. Open those documents and compare what the client is asking now to what was asked in the previous audit. Many of the answers will remain the same and, you can copy and paste again. Where there are new questions, see if another client recently asked the same thing. For instance, clients have always wanted a letter process, but now clients are also asking for an email policy. Perhaps a client used to ask a basic question like, “Do you have a Firewall?” Now the question is not whether we have a firewall, but “What is the name, version and latest update of your Firewall?” Once one client begins asking more specific questions, ready yourself for all the other clients to follow, and update your quick-reference guide accordingly!
Follow Your Plan
Audits are never fun (at least not for me), but they do not have to be a total time drain, except when you get multiple requests at the same time! By taking the time to create a plan to save important documents and to create a list of important knowledge items (e.g., firewall software and version), you can become fairly efficient at completing audits, leaving you time to work on and update the policies for the new manual the client just published!
By Brit J. Suttell, Esquire, Director of Compliance
Ms. Suttell is Director of Compliance at Burton Neil & Associates, P.C. She is an ACA International certified Credit & Collection Compliance Officer. She graduated from Mount Holyoke College in 2003 and received her JD from Seattle University School of Law. She is licensed in Pennsylvania, where she has been practicing for over 8 years. When not in the office, she enjoys playing tabletop board games and often enforces the rules on her friends. She can be reached at:
Burton Neil & Associates, P.C.
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610.696.2120 ext. 260
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