
January 1994
WHEN TO AUDIT
A Risk Issue
The question was asked, "Is there anyone using a risk model to determine how often to audit their
agencies?" Good question. We didn't know anyone, so we started asking. No risk models were
uncovered, but definite opinions on when to audit were.
"If anyone would be using a risk model to determine exposure and when to audit, it would be my boss,"
one recovery professional said. "He's always doing measurements and modeling with recovery. But,
we're not." "I don't think anyone is," was a common conjecture.
In a subsequent informal telephone survey of larger credit grantors, no detailed, statistical risk modeling
formula was found, but definite opinions and ideas were stated regarding the risk of auditing and the
appropriate time frame.
Some of those responses are listed below:
- Our auditing decision is influenced less by risk and more by staffing, cutbacks and priorities. We do
a blanket plan with monthly audits for our instate agencies and every other month for our out-of-state
agencies. A risk model would be great. Please let me know more about it.
- Well, we've discovered that once a year is not enough; quarterly is too much. I strive for three at
different times of the year. It allows for two good audits and one follow up. There is risk with the
amount of dollars, but less risk with a strong manager and a good management process. The when
to audit question depends on how you manage, how often you talk to the agencies and the total
process.
- We believe it is important to be on-site at the agencies every month, whether we need it or not, no
matter what the recovery numbers look like.
- Our company audits on a predetermined schedule both on-site and off-site. We look at trends for
specific areas of interest. For example, we look for heavy NSF activity. There are a lot of factors
in the decision of when to audit.
- We've gotten a new portfolio. We're auditing monthly to check activity until we can develop the
appropriate liquidation curve. Once that is developed, we'll audit as necessary, probably quarterly,
but more often as needed, particularly if the liquidation is not at expectations.
- Monthly.
- Not as often as we probably should.
In a recent survey of creditors, (Comprehensive Agency Usage Study by Resource Management Services,
Inc.), 64.8% of respondents indicated that they audit their agencies. Most often this audit is conducted by.the collection or recovery manager (57.2%), but it is conducted by the internal auditor at 20% of the
companies that audit.
The most common response, 29.9% of the respondents, indicated annual audits. Twenty-four percent
indicated that they audit "As the Need Arises". Twenty-one percent of the respondents audit quarterly.
Monthly audits are conducted by 6.9% of the overall respondents. The frequency of the audits also varies
greatly by industry. Bankers were most likely to perform quarterly audits (31.6%). Retailers were most
likely to audit annually (50.0%). Telecommunications companies are most likely to audit annually, with
37.5% of the respondents listing that option. Commercial and manufacturing companies list both
annually (37.5%) and as need arises (37.5%) more often than other time periods.
Whether it is a direct reflection of risk or other factors is undeterminable, but creditors who place less
than $1,000,000 per year audit less often than others. In fact, only 25.8% of respondents placing less than
$1,000,000 per year indicated that they audit their agencies. In the annual placement range from
$1,000,001 to $10,000,000, 78.2% of creditors indicate they audit agencies; 34.9% annually, 18.6%
quarterly; 2.3% monthly, and 34.9% as the need arises. In the $10,000,001 to $50,000,000 range, 82.7%
of creditors indicate that they audit agencies; 34.0% annually, 20.5% quarterly and 20.5% as the need
arises, 13.6% semiannually, 6.8% a combination, and 2.3% monthly and other.
Eighty-nine percent of creditors placing over $50,000,000 per year audit their agencies. Their most
common time period, 32.4%, is quarterly. The next highest response was annually, with 17.6% of the
respondents.
When reviewing the responses based on number of accounts placed and audit frequency, the trends are
similar. Twenty-five percent of creditors placing more than 50,000 accounts per year audit annually.
Twenty-two percent of the creditors placing more than 50,000 accounts per year audit quarterly. Twenty
percent of creditors placing more than 50,000 accounts per year indicate that they audit as the need arises.
Fourteen percent of creditors placing over 50,000 accounts per year indicate a combination of audit
timing. Monthly and semiannually were the least common responses for creditors placing over 50,000
accounts per year, with 8.6% each.
Creditors appear to audit differently, and for a variety of reasons, each reflecting various degrees of risk
and risk aversion. Risk concerns can be classified in four categories:
- Agencies That Don't Collect Maximum Dollars - Creaming
- Agencies That Don't Remit All Dollars Collected - Cheating
- Agencies That Are Not Financially Stable And Don't Remit - Bankrupt / Out of Business
- FDCPA Violations; Harassment of Debtors; State Violations & Possible Creditor Liability
Many creditors who audit regularly acknowledge that part of their collection results are from their
consistent vigilance and they believe in the "squeaky wheel gets the grease" theory. Their on-site
attendance and verification of activity serves many purposes:
- provides an opportunity to check that work standards are being adhered to;
- it allows for hearing how the collectors talk to the debtors and verify that FDCPA requirements
are being met;
- allows for a review of mail opening, accounting procedures and checks and balances; and,
- provides for interaction and communication with the agency regarding any relevant issues.
On-site visits won't automatically ensure that agencies aren't cheating and that they will remain financially
stable. There are additional audit efforts that can help to provide a comfort level in these areas. One way
would be to send debtor verification letters to debtors requesting they verify the amounts paid to the
agency. Another method is to place dummy accounts and send payments to the agency and watch to see
when the account is remitted to the client. Historically, financial stability of an agency was often
assumed, since agencies work on commission. Unfortunately, this does not guarantee that the agency is
profitable, or runs an efficient organization. Even large agencies have gone bankrupt, or out of business.
Size won't guarantee financial stability either. An audit should include steps to verify financial stability in
addition to work efforts.
Two likely quantitative measures for determining when to audit might be the number of accounts placed,
or dollars at risk. Or, another measure could be based on a calculation of expected liquidation percentage
multiplied by dollars placed. However, recovery and dollars placed statistics are not the only factors
involved in the audit timing decision by creditors. Other factors certainly enter the picture. When
assessing risk, the recovery professional also needs to ascertain his or her company's degree of risk
aversion. Efforts can be made to minimize the maximum risk, or maximize the potential gain. Degree of
management involvement, additional auditing efforts, number of agencies and even choice of agencies
can all be based on a company's risk attitude, or degree of risk aversion. This is one step in determining
an appropriate risk model.
Decision tables can be developed which consider several possible scenarios with given probabilities of
occurrence. Or, decision tables can be developed examining uncertain situations, where several outcomes
are possible for each course of action and the decision maker does not know the probability of the
occurrence of various scenarios. Decision tables can also be developed where the decision maker can
assess the degree of risk that he or she is taking and assign an appropriate probability factor.
At the present time, decision theory does not provide a single best criterion for selecting an alternative
under conditions of uncertainty. Instead, there are a number of different criteria, each with its own
justifications and limitations. The choice depends on the attitude of the decision maker and organizational
policy. Ideally, decision making under uncertainty should be avoided and enough current information
should be acquired so that more informed decisions can be made.
The recovery professional may recognize that the placement of accounts at an agency, the right number of
accounts, type of accounts, right agency, etc. can all be factors. The next question would be, "If
additional information is available, what would be the added value of that information?" This would
involve looking for the expected payoff with "perfect information". The question of "should the
additional information be required, and at what cost?" arises. Using a recovery example, could the
recovery manager make a better decision regarding where to place accounts based on additional
information provided by auditing? If so, what level of auditing would be appropriate? These are not easy
answers. Since they rely on organizational policy and risk attitude, these answers won't be identical for
all companies, or industries.
Some non-quantifiable ways recovery managers can lessen risk include:
- Detailed, Appropriate Initial Selection Criteria & Process
- Solid Agency Contractual Relationship
- Strong Recovery Management Team and Agency Follow Up
- On-site Agency Presence & Auditing
- Internally Generated Recovery Statistics & Batch Tracking
- Diversification (More Than One Vendor)
Reducing risk will have increased costs associated with it. Determining that level of profitable activity
that minimizes risk and results in maximum recovery is just one facet of the recovery manager's challenge
and opportunity.
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