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NEWS REPORT
Bankruptcy Reform Legislation
Spurs DMP File Changes
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| MasterCard RPPS Leadership Facilitates Quick Delivery
of Optional Solution |
In July, the Executive Office for U.S. Trustees (EOUST) made public its
administrative rules implementing the requirements of the Bankruptcy Abuse
Prevention and Consumer Protection Act. That gave the credit counseling industry
just three months to prepare for a radically different environment.
"On August 10, we convened a meeting of the MasterCard RPPS Credit Counseling User Group to discuss what network changes would be required to accommodate the new law in the short term," says Janet Smith, vice president, MasterCard RPPS Product Management and Account Support. "We invited creditors, processors, and credit counseling agencies of all sizesa representative sample of our
credit counseling industry stakeholders.
"The meeting was very successful. We came to a consensus on a nearterm solution," she says. "When the law went into effect on October 17, MasterCard RPPS was ready to support our credit counseling customers' needs."
Identifying need
Under the new bankruptcy law, most consumers will be required to attend
a session with an EOUST-certified counselor as a prerequisite to filing for
bankruptcy. In the session, consumers will be informed about the advantages
of credit counseling assistance and, as appropriate, encouraged to enter into a
debt management plan as an alternative to bankruptcy.
To understand how the provisions of the legislation would affect our customers,
MasterCard RPPS conducted customer interviews and a survey prior to the user
group meeting.
"By understanding the real issues in advance of the meeting, we were able to
focus the large user group on identifying an effective near-term solution that could be developed and deployed by October 17, 2005," says Smith.
At the meeting, four essential requirements emerged from the discussion. MasterCard RPPS customers would need
- A prebankruptcy client-type indicator
- The capability to submit less-than-fullbalance proposals
- A method for communicating the percentage of the balance to be paid
as well as the repayment term for any less-than-full-balance proposals
- Flexibility to choose to participate in the new solution or not
A quick and elegant fix
Smith's team released the agreed-upon solutions for comment to the attendees.
Their feedback and additional input from MasterCard RPPS were incorporated
into the MasterCard RPPS Credit Counseling Product Update Guide that
was then released to all credit counseling customers. (The guide may be accessed
in the News Center on the Credit Counseling section of the MasterCard
RPPS Web site.)
The solution allows transmission of the additional information using refinements
to existing fields within the electronic DMP files.
"We were working under very tight time constraints, but the beauty of
our solution is that it fulfills the basic needs of our customers with
minimal impact on their operations," Smith says. "Agencies will be able to
submit the prebankruptcy indicator and the less-than-full-balance proposals,
along with the term and percentage of balance to be paid, and they will be
ablevia our online directoryto identify which creditors will accept
this information.
"Creditors will be able to receive the information, but they can also opt out
of seeing the prebankruptcy indicator or receiving less-than-full-balance proposals."
The solution is entirely optional. Neither agencies nor creditors are
obligated to participate.
Testing procedures and time frames were also communicated to customers.
"Originators can conduct self-testing, but creditors need to schedule testing with us," Smith says.
Looking ahead
MasterCard RPPS will convene another meeting of the Credit Counseling User
Group to evaluate performance of the near-term solution and focus on longterm
answers.
"Our customers have a lot of good ideas about how they'd like to see the DMP
file formats change overall, and we also may see new rules from EOUST," says
Smith. "So in 2006, we'll begin assessing the long-term needs of our customers to deliver an even more robust offering for the credit counseling industry.
"We're proud of the focus that we and our customers brought to the immediate
challenge, and of the solution we developed together. In a few short weeks,
we've listened to what our customers told us, developed a viable solution, and
deployed the changes. It's been a very successful effort all around."
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