Collection Policies and Procedures: Debtor and Governmental Agency Complaint Handling

A. Manager Referral

Each time a complaint concerning the manner in which an account is collected is received with respect to a specific incident of conduct by an LGW employee, the complaint be referred to the Collections Supervisor and the Managing Attorney. The Collection Supervisor shall be primarily responsible for addressing complaints received from Debtors regarding alleged conduct of members of the collection staff. All Debtor complaints that can not be satisfactorily resolved by the Collection Supervisor shall be immediately escalated to the Managing Attorney. All complaints received from federal, state or local governmental agencies shall be addressed in the first instance by the Managing Attorney.

B. Complaint Handling

The collection department is responsible for maintaining a written log of all complaints received. The Collections Supervisor and the Managing Attorney must review any complaint received with all associates who worked on the account or spoken to the Debtor prior to responding to the Debtor's complaint. The Managing Attorney must review and approve any written response to the Debtor or governmental agency. All collection activity must be suspended upon receipt of any Debtor, agency, or governmental complaint until all issues raised are addressed and resolved. A written summary of the response / resolution provided to the Debtor or governmental agency must be placed in the Debtor's account history notes as well as the separate complaint log. The written response must also be scanned for inclusion in the document images maintained as part of the Debtor's account records.

C. Violation of Policy

If the investigation of the Debtor's or governmental agency's complaint reveals a violation of law and/or LGW collection policy by the collection associate, the associate must be specifically reminded of his/her obligation to comply with all statutes and regulations concerning consumer debt collection as well as LGW collection policies and additional training shall be provided to the collection associate as necessary. Disciplinary measures, up to and including termination of employment, shall also be taken as appropriate. All such corrective measures, whether involving a single collection associate, or a group of associates, shall be placed into the personnel file of the associate(s) involved.

D. Notification to Client

Immediately upon receipt of a Debtor complaint or a complaint from a federal, state or local agency or regulatory authority it shall be the responsibility of the Managing Attorney to notify the client(s) involved and to provide the client(s) with a copy of the complaint received and the firm's response thereto.