Collection Policies and Procedures: General Rules

A. Basic Approach

It is essential that LGW collection personnel maintain the good image of LGW and its creditor clients. At no time shall an LGW associate use any misrepresentation or deception in attempting to collect an account. All business must be conducted in the name of the caller or in the name of "LGW". Under no circumstances may an LGW associate represent him/herself as being an employee of the creditor, a representative of a credit bureau, collection agency, or any third party organization. All statements made by a collection associate to any other party must be true and correct. No abusive, belittling or un-businesslike language may be used at any time. No threat to take action on an account shall be made by anyone collecting for LGW, including a threat to take legal action, unless such action can be taken and will in fact be taken should arrangements for payment not be made. Collection Associates may advise a consumer that a specific action will be taken only if such action has been fully approved and LGW intends to take such action.

B. Record Keeping - Conversations with Debtors, Etc.

Concise notes, using readily understandable abbreviations, must be made of the subjects covered in a discussion with a debtor, or other party, as appropriate. Collection notes must include summaries of statements and promises made by either party during the contact.

C. Letters and Forms

Only forms approved by the Managing Attorney in charge of the Collections Department are to be used by LGW in the course of business. Any written communication other than those on approved forms must be specifically approved by the Managing Attorney. No correspondence indicating that its origin is from LGW that concerns collection of a debt should be sent to or left with unauthorized third parties. Whenever possible, only authorized, computer generated letters should be utilized. All written communication to the debtor shall advise the debtor that the communication is from a debt collector and the initial written communication shall also advise the debtor of his/her debt validation and so-called "mini-miranda" rights.