Vendor auditing best practices that will help your organization succeed

by Guest Contributor 5 min read March 29, 2012

Jeff Bernstein Experian Global Consulting Practice Risk Management

Auditing provides the organization with assurance that all financial controls are in place to ensure that trust account funds are maintained, access to financial records at the vendor location is tightly controlled, customer data is secure, and that the vendor is in full compliance with contractual requirements (i.e., minimum account servicing requirements for issues such as vendor actions following initial placement, ongoing contact efforts, remittance processing, settlement authorizations, etc.).

There are two basic auditing processes that occur from a best practices perspective. The first one is fairly common, and involves use of an on-site audit.

Onsite Auditing

The onsite audit is required to examine financial records involving customer transactions, accounting processes, trust accounts and remittances, IT and security for handling sensitive customer information and records, and documentation of the processes that have occurred towards customer communication, contact efforts and results.

There are differences of opinion as to both the frequency of onsite audits, and whether they should be announced or unannounced. Frequency is primarily an issue of the size of the overall vendor relationship and the degree of financial risk associated with a default, typically involving the trust account and legal exposure to litigation and brand reputation risk.

Most utilities should follow an annual onsite audit schedule due to size of portfolio and attendant financial exposure. While surprise audits have the advantage of reducing any opportunity by the vendor to potentially alter records to cover up what would normally be audit violations, it does result in a more time-consuming audit schedule onsite, as the vendor is unable to prepare and have documentation available. The use of substantial online documentation lessens this issue, but nonetheless, there is more work to do onsite when nothing has been captured for review in advance. The other issue is that key managers from the vendor may not be available on the dates of a surprise audit.

One way in which organizations chose to resolve the issue of surprise versus planned audit is to conduct one pre-planned and announced audit annually, and a smaller scaled unannounced onsite audit annually at least 2 quarters separated from the planned audit. The use of remote auditing and monitoring lessens the requirements for onsite audits in certain areas, other than IT / Security, financial and compliance.

Remote Auditing / Monitoring

Remote auditing and monitoring of vendors is a stronger tool for credit grantors to improve performance of agencies, in that it combines some of the same auditing checks to ensure compliance and quality of collections with an added value of focus on performance.

The best tool in the arsenal is the use of digital logging to capture the collection call between the vendor and customers. When digital logging technology first came into use, it was cost prohibitive for collection agencies, and not fully accepted by the industry due to its possible use in litigation against the agencies. Over the past decade, as the costs of deployment have lessened, and agencies became more attuned to customer satisfaction and full FDCPA compliance, more agencies have installed digital logging into their call centers.

Most agencies that utilize digital logging capture every customer contact effort that results in either a right party contact, or third party contact for messages, etc. Many of those agencies will tag each of these voice records as to whether they were a right party contact or not. The intent is to be able to audit more frequently those calls that were right party contacts, so that collector skills can be assessed in terms of how they managed the customer, their ability to create and sell payment solution, and ability to negotiate successfully with the customer.

Typically, an organization that is using digital logging will have an internal quality assurance team that will create a compliance audit process that establishes a number of right party and non-right party contacts per collector. These calls are typically evaluated using a scorecard approach, and used for training purposes. They might alter the frequencies of monitoring based upon the tenure of the collector, their performance levels, and the results of prior monitoring, such that sample sizes are affected.

Utilities and other credit grantors should have access to the entire inventory of raw digital log files for their projects and randomly audit them remotely. These should not be “assembled” or pre-selected by the vendor, so that there is no undue influence in deciding which calls / collectors to review. If the vendor is using a QA monitoring / compliance program and separately maintains a scorecard driven monitoring process, the credit grantor should have access where those calls and evaluations related to their own customers and contacts.

The intent of the process is to listen for both quality of the communication with the customer from the perspective of effectiveness, but also to ensure compliance with FDCPA and that the customer was treated with respect and appropriately. Typically, a credit grantor would establish a remote monitoring schedule where x calls across the agent pool handing their assigned portfolio are monitored and evaluated with a simple checklist. Ideally, the credit grantor should be listening to a range of 100-150 right party contacts per month, based upon overall inventory and activity, but typically no more than 1-2% of the total right party contacts per month on their customer accounts.

The credit grantor should provide monthly feedback to the agency regarding the monitoring of quality and compliance, noting any compliance or policy violations, and any concerns relating to customer contact quality and performance.

Other aspects of the remote auditing that occurs each month should include ensuring that all servicing requirements are met. As an example, we would expect that the agency should perform various external checks for bankruptcy, deceased, etc. before initiating contact once the file has been received from the credit grantor as a placement. These database checks should be performed within the first 24 hours once placed, and then a letter of representation should be sent to those not flagged. The initial call to the customer should also occur within 24-48 hours from placement by the credit grantor, subject to phone number availability. Skip trace processes should commence immediately on those without phone numbers. There are requirements for how often accounts are attempted for contact, and settlement authorizations. All of these requirements are subject to the remote monitoring that is performed to ensure these are met.

Coming soon... Best practices for improving agency performance.

Related Posts

Why Innovation Matters for Members First Credit Union

Learn how Members First Credit Union uses innovation and data-driven insights to better serve members and expand financial opportunity.

July 24, 2026 by Scarlet Nickel
Ask the Expert: Unlocking the ROI of alternative data with Natasha Madan and Julius Heim

A visibility gap lenders can't afford to ignore Alternative data is often associated with thin-file or credit invisible consumers. But its value extends far beyond those segments. Experian's Clarity Services database includes approximately one in five credit-active consumers, including one in four consumers with prime-and-above credit profiles. That means lenders may be missing important signals, not only for emerging borrowers, but also for applicants who appear well qualified using traditional bureau data alone. Consider two consumers with the same credit score. Based on traditional credit data, they may appear equally creditworthy. But when Clarity data is added, one consumer may demonstrate stable repayment behavior while another shows recent defaults on alternative finance products. The credit score hasn't changed, but the decisioning context has. That's where alternative data creates value: helping lenders distinguish between consumers who look similar on paper but represent very different levels of risk and opportunity. In this Ask the Expert session, Experian’s Julius Heim, Vice President of Analytics Product Build, Innovation and Scores, and Natasha Madan, Senior Director, Analytics Consulting, explain how different alternative data assets solve different business challenges and why the greatest return comes from using them together throughout the credit lifecycle. What that visibility gap is really costing lenders Better visibility matters because every lending decision carries consequences. Without alternative data, lenders may approve applicants whose repayment behavior suggests elevated risk but isn't reflected in a traditional credit file. Without cash flow insights, they may decline consumers who appear thin file on bureau data despite demonstrating strong income and responsible financial management. The result is a two-sided cost: avoidable bad debt on one side and missed growth opportunities on the other. But ROI extends beyond approvals alone. It also appears through stronger marketing strategies, improved conversion, reduced friction and more precise risk segmentation throughout the lending lifecycle. "ROI can mean many things ... marketing to the right people, achieving better approval rates, reducing risk, getting less friction and overall profitability."Julius Heim, Vice President of Analytics Product Build, Innovation and Scores Where alternative data creates ROI Improve approval strategies Use additional consumer signals to recover creditworthy applicants while avoiding unnecessary declines. Reduce portfolio risk Identify elevated repayment risk earlier through enhanced visibility beyond traditional bureau data. Improve portfolio performance Increase conversion, reduce friction and strengthen profitability across the credit lifecycle. Different data. Different jobs. Not all alternative data solves the same problem. Clarity Services can help lenders strengthen decisions early in the customer journey. It provides additional visibility during prospecting and acquisition, helping identify potential risk before an application moves through the underwriting process. Cash flow insights can provide value in a different way. When traditional credit information offers part of the picture, consumer-permissioned cash flow data can provide greater insight into income, spending patterns and financial capacity. That makes it especially valuable as a second look during underwriting. Together, these complementary data assets help lenders improve decisioning throughout the credit lifecycle. They can support acquisition, underwriting, account management and collections while building on the trusted foundation of traditional bureau data. Research also continues to demonstrate measurable lift when cash flow insights are combined with traditional credit information. "I recently did a study with a client where we actually saw a 20% lift in KS [Kolmogorov-Smirnov] above and beyond credit bureau data. Again, the bureau data itself was very predictive. But even from the cash flow data, we still got a 20% lift, which is an amazing stat." Julius Heim, Vice President of Analytics Product Build, Innovation and Scores The greatest value comes from using these data sources together for a more holistic consumer view. Start with proof, then build Adopting alternative data doesn't have to begin with a large transformation. A practical first step is a data study. By comparing current decision strategies with enhanced data, lenders can identify where additional visibility creates measurable lift within their own portfolios. This approach allows institutions to validate results before making broader operational changes. Every lender has different workflows, technology environments and business priorities. A flexible implementation strategy helps organizations incorporate new data in ways that support existing processes rather than disrupting them. Three ways to get started Run a data study Benchmark current decision strategies and quantify potential lift. Start simple Begin with targeted data attributes or proven scores before expanding to more advanced use cases. Build with confidence Scale implementation based on measured business outcomes and organizational priorities. This approach allows lenders to validate results, build confidence and expand their strategy over time. Explore alternative data with a trusted partner Every lending decision benefits from better consumer insight. Experian helps lenders combine trusted credit data with alternative data, cash flow insights and advanced analytics to strengthen decisioning, improve portfolio performance and uncover new opportunities for growth. Whether you're evaluating alternative data for the first time or expanding an existing strategy, Experian can help you identify where additional consumer insight can create measurable business value. Learn more Contact us About our experts Julius Heim Vice President of Analytics Product Build, Innovation and Scores, Experian Julius Heim works at the intersection of financial services, analytics and innovation. He focuses on leveraging data to drive smarter decision-making and support more inclusive financial ecosystems. Julius brings a practical perspective on how organizations can translate insights into real-world impact, with particular interest in emerging trends across fintech, credit, and the use of alternative data, such as cash-flow data, across the credit lifecycle. Previously, he served as Head of Analytics on the lender side and held roles in insurance analytics earlier in his career. Natasha Madan Senior Director, Analytics Consulting, Experian Natasha Madan partners with lenders to drive smarter, data-driven credit and risk decisions. She specializes in leveraging alternative data and advanced analytics to help organizations improve portfolio performance, optimize customer acquisition, and expand responsible access to credit. During her 15 years at Experian, Natasha has held leadership roles spanning data analytics, product analytics and consulting, giving her a broad perspective of how data can be leverage to solve complex business challenges. She has worked with a diverse range of lenders – including banks, credit unions, fintechs and specialty finance companies to develop analytics strategies that optimize customer acquisition, underwriting and portfolio management. Natasha is passionate about helping organizations unlock the full potential of data to improve both business outcomes and consumer financial inclusion.

July 24, 2026 by Julie.JLee@experian.com
Advancing Homeownership Through Partnership 

Learn how HomeFree-USA and Experian partner to expand financial education, strengthen communities and help consumers achieve homeownership.

July 22, 2026 by Scarlet Nickel