Compliance

In the New Age of AI, Good Judgment Is the Competitive Advantage

By Tim Fleury, Chief of Staff, DCM Services

As artificial intelligence and automation become more common in highly regulated industries, the challenge for business leaders is shifting their approach while staying compliant. The question is no longer whether these organizations should adopt AI, but where and how it should be used.

The organizations that gain the greatest advantage won't necessarily be the ones that automate the most. They will be the ones that exercise the best judgment about when it’s warranted, or even responsible to use AI, when human oversight is necessary and when people should remain at the center of the customer experience.

That distinction matters in regulated businesses, where efficiency is only one measure of success. Compliance, information security, customer experience and trust matter, too.

The question for leaders is no longer simply what AI can automate. It is what AI should automate.

Where Should Companies Use AI and Automation?

One of the easiest mistakes organizations can make is starting with the technology and then looking for places to deploy it.

A better approach is to start with the work. Asking questions like these give a much deeper and more valuable insight into opportunities for AI to supplement your workforce:

  • Where are employees spending time on repetitive, administrative activities?

  • Where could automation improve consistency?

  • Where could AI free people to focus on higher-value work?

  • Where does the work require context, empathy or judgment that technology cannot adequately replicate?

Asking yourself those questions help establish a natural division between tasks that can be automated, work that can be augmented by technology and responsibilities that should remain human.

We've seen that distinction firsthand at DCM Services. Many of the interactions our teams have involve people navigating the loss of a loved one. That makes it especially important to be deliberate about where technology fits.

We use AI to support defined administrative activities such as call preparation and documentation, helping create more consistent and complete records while allowing representatives to focus more fully on the conversation. AI also supports quality review, enabling us to evaluate more interactions consistently.

The objective isn't to remove the person from the process. It's to make that person more effective.

In that sense, one of the most valuable applications of AI may be surprisingly human: using technology to create more room for people to be people.

Why Is Human Judgment Still Essential?

AI is powerful because it can process information, recognize patterns and perform well-defined tasks quickly and consistently. But consistency and judgment aren't the same thing.

That distinction becomes especially important when customer interactions are sensitive or complex.

A model can recognize patterns in language. A skilled representative can hear uncertainty or emotion in someone's voice and adjust the conversation. They can recognize when slowing down matters more than completing an interaction quickly and can apply context that may never appear explicitly in the data.

At DCM Services, we hire and train specifically for those human capabilities because empathy and listening are central to the work our representatives do. AI can support that work, but it isn't a substitute for the judgment required to do it well.

The same principle applies more broadly across regulated industries. Businesses routinely encounter situations that are ambiguous, sensitive or context dependent. A process may have clearly defined rules while still requiring someone to determine how those rules apply to a particular situation.

Human oversight is what determines when automation is appropriate rather than simply being a signal of there being a failure of automation.

As AI becomes more capable, leaders will increasingly have to distinguish between whether a machine can perform a task and whether it should perform that task independently.

How Should Regulated Companies Govern AI?

In regulated environments, AI governance cannot be separated from AI innovation.

Once technology has been deployed, it’s too late to worry about data privacy, information security, regulatory obligations, client requirements and internal controls. Those issues have to be considered from the beginning before you commit the time, money, and energy into adopting new technologies or automations.

There is sometimes an assumption that governance slows innovation. I see it differently.

Strong governance is what makes sustainable innovation possible.

A compelling demonstration of what an AI tool can do isn't enough to establish that it is appropriate for a business environment. The technology must perform under real operating conditions. Output needs to be evaluated for relevance, efficacy, and compliance. Risks have to be understood. Appropriate human review procedures should not only exist but be settled upon before rollout. And sensitive information must be protected.

Our experience at DCM Services has reinforced the importance of that discipline. We operate in an environment where compliance, data security and quality control are already embedded in how we do business, and we believe AI should be held to that same standard. We start with defined use cases, pilot them in a controlled way, evaluate the quality and accuracy of the output, and maintain human review before relying on that output operationally. Just as importantly, data privacy is a design consideration from the outset: customer data isn't used to train models, and AI applications must operate within our existing security and compliance framework.

For us, responsible AI isn't a separate governance exercise layered onto the technology after the fact. It's an extension of the controls, risk management and accountability already expected in a highly regulated business. That discipline gives us the ability to explore where AI can create value without lowering the standards our clients and their customers expect. The business case for automation therefore can't be evaluated solely on operating efficiency.

A technology that reduces operating costs while introducing unacceptable compliance, customer or reputational risk hasn't eliminated costs. It has simply shifted them.

In regulated industries, trust has to be part of the return on investment.

When is an AI Use Case Ready to Scale?

The speed of AI development creates understandable pressure to move quickly from experimentation to enterprise-wide adoption. A disciplined implementation begins with a clearly defined business problem and a controlled use case. Organizations can then evaluate accuracy, security, operational impact, compliance implications and the experience of the employees and customers affected before expanding it.

Leaders should ask a few straightforward questions:

  • Does this solve a meaningful business problem?

  • Does it improve the experience for employees, customers or clients?

  • Can it operate within our security, privacy and compliance requirements?

  • Do we understand where human judgment is still necessary?

  • Can we demonstrate that it is producing a better outcome?

These questions create a more durable framework for AI adoption than pursuing the newest capability simply because it is available. Technology will continue to change. Models will become more capable. Economics will evolve. New use cases will emerge. That makes the framework an organization uses to make decisions about AI just as important as the technology itself.

Why Judgment Will Become a Competitive Advantage

As AI becomes more accessible, many of the capabilities that appear differentiating today will eventually become widely available. Organizations will increasingly have access to similar models, tools and automation platforms. Simply having AI is unlikely to create a durable competitive advantage.

The differentiator will be how organizations choose to use it.

Companies that understand their customers well enough to recognize where automation improves an experience and where it diminishes one. Responsibility rests with the leaders who recognize that technological capability and business wisdom are not the same thing.

For highly regulated organizations, this doesn't require choosing between innovation and compliance or between automation and human connection. The opportunity is to design systems in which each reinforces the other. AI can improve consistency, reduce administrative work and help organizations evaluate information at a scale people alone cannot. It can also give employees more time to focus on the work requiring their expertise, empathy and judgment. But realizing those benefits requires knowing where the boundaries should be.

As AI becomes ubiquitous, access to technology will become less differentiating. The judgment surrounding its use will become more differentiating.

The organizations that lead in the age of AI won't simply be those with access to the best technology.

They will be the ones with the judgment to know how and when to use it.


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The Hidden Cost of Treating Every Delinquent Account the Same: Why Specialty Collections Matter

The Problem with Using Standard Collections Procedures for Specialty Situations

Consumer lending portfolios are built for scale. Standardized procedures, automated communications, segmentation and consistent performance metrics let collections organizations manage thousands, or even millions of accounts without a person reviewing each one individually.

While that scale is the whole point of standardization, it's also its blind spot. Not every delinquent account behaves like a standard delinquent account, and running one through the standard machine can quietly create compliance exposure. This can cost real recovery dollars, often without anyone noticing until someone performs a diagnostic check. The gap between special delinquency circumstances and their discovery is where specialty collections comes into play.

When a Standard Account Becomes a Specialty Collections Case

A delinquent account can leave the standard collections path the moment certain circumstances enter the picture: a borrower's death, an open probate estate, a bankruptcy filing, active litigation, or a third party (e.g., an executor, guardian or attorney) now acting on the borrower's behalf.

Take the scenario of a deceased borrower. A conventional collections cadence of calls and letters doesn't answer the questions that matter now: Has the death been verified? Is there an estate? Is it in probate? Who has legal authority to act on its behalf? What's the actual process for resolving the balance?

The account may still be a legitimate recovery opportunity; the path to get there has just changed. The issue arises when probate and estate deadlines don't wait for a conventional collections procedure to catch up. The real challenge is recognizing it fast enough, and consistently enough, across a portfolio of potentially millions of accounts, that specialty cases don't get missed.

Standardization Has Limits

Standardization exists in collections to create consistency, reduce error and give compliance teams a known set of rules to monitor against. However, a single standardized procedure applied to every account becomes a liability the moment an account's circumstances no longer match the assumptions on which that procedure was built.

The scale of the underlying portfolio can really raise the stakes for these special cases. The Federal Reserve Bank of New York reported $18.8 trillion in U.S. household debt for Q1 2026, with delinquency transitions remaining elevated across some consumer credit products. A larger, more delinquent universe of accounts means a larger number of accounts that will, statistically, fall outside the standard path and need specialty collections handling instead.

The regulatory backdrop hasn't gotten simpler either. The CFPB's examination procedures reach into communications, information sharing and privacy, dispute handling, payment processing, account maintenance and litigation practices. Additionally, Regulation F sets specific requirements around validation information, disputes, communications and record retention. None of that pauses for an account that doesn't fit the standard model.

For leadership, the conclusion isn't that standardization is the wrong model. It's that standardization is incomplete without a deliberate specialty collections strategy for the accounts that fall outside it.

The Cost of Skipping a Specialty Collections Strategy

When specialty accounts aren't identified early, the costs show up in more than one place:

  • A collections team spends real hours working an account through a process that was never going to resolve it.

  • Staff try to research estate status, probate filings or legal representation, which work internal teams are rarely equipped to do efficiently.

  • Deadlines that are crucial for recovery, like probate claims windows, bankruptcy stays, litigation holds all get missed because no one flagged that they applied.

  • Compliance teams inherit the risk created by contact and collection activity that was never designed for an account in that state.

Make Specialty Collections Part of the Strategy

A mature collections operation can think about its portfolio along two tracks:

Standard accounts: Move efficiently through established collections processes, where the existing workflow is designed to work.

Specialty accounts: Call for specialized identification, research, compliance handling and resolution strategy and include death, probate, bankruptcy, active litigation and similar events.

Making that distinction explicit lets an organization preserve the efficiency of its core collections engine while giving specialty accounts a deliberate, purpose-built path to resolution.

Treat Exceptions Differently

Every delinquent account starts in the same portfolio. That doesn't mean every account belongs in the same workflow. For lenders and servicers, building specialty collections capability into the broader recovery strategy is a way to reduce compliance risk, cut wasted effort and capture recovery opportunities that a standard workflow would otherwise miss.

The question for your organization is whether you are running every delinquent account through the same process and, if so, how much it’s costing you.

DCM Services can help!

We specialize in identifying and resolving deceased and court-supervised accounts. Our proprietary technology automates date-of-death verification and probated-estate identification, helping organizations flag specialty accounts early and route them to the right resolution path before those accounts absorb effort they were never going to be resolved by, or create compliance exposure standard collections procedures were never built to handle.

Contact us to learn how our specialty collections solutions can help your organization identify, manage and resolve the accounts that require a different path to recovery!

Decedent Account Recovery for Auto Lenders Fixes a Growing Revenue Leak

Auto Lenders are Facing an Increasing Number of Hurdles to Reduce Write-Offs and Maintain Compliance

Auto lending has changed dramatically over the past decade. Loan balances are larger, repayment terms are longer, and portfolios have become increasingly complex. While lenders continue investing in analytics, collections technology, and servicing strategies, one area often remains reactive: managing accounts after a borrower passes away.

An effective decedent account recovery partner can help lenders identify deceased borrowers sooner, pursue estate recovery opportunities before critical deadlines expire, and improve compliance throughout the recovery process. Rather than allowing these accounts to become unnecessary charge-offs that hurt their bottom line, lenders can implement proactive workflows that protect revenue while delivering a more compassionate experience for surviving family members.

Whether you're responsible for portfolio performance, collections operations, or regulatory compliance, understanding how deceased accounts impact recovery is becoming an essential part of modern auto lending.

Why a Proactive Decedent Account Recovery Procedure Matters More Than Ever

Vehicle prices continue to climb significantly. Loan amounts continue to reach record levels. Longer repayment terms mean borrowers remain in portfolios for six, seven, or even eight years. At the same time, more Americans continue financing vehicles later in life, increasing the likelihood that lenders will encounter deceased borrowers during the life of a loan.

According to the Consumer Financial Protection Bureau, auto loan balances have continued to grow while borrower demographics and lending patterns have shifted over time. These long-term trends create new operational challenges for lenders managing large consumer portfolios. When those accounts aren't identified early, the financial consequences extend well beyond missed payments. Accounts may continue through traditional collection procedures, probate deadlines can pass unnoticed, and opportunities to recover through an estate may disappear entirely. The result is avoidable charge-offs, unnecessary operational costs, and increased compliance risk.

Trends Auto Lender Leadership Should Monitor

Rising Loan Balances are Increasing Financial Exposure

The average financed vehicle costs considerably more than it did just a few years ago. Larger balances mean every unrecovered account represents greater potential loss. The Federal Reserve Household Debt and Credit Report continues to show auto loan balances at historically elevated levels, increasing lenders' exposure when loans become unrecoverable. When borrowers pass away before repayment is complete, even a small percentage of missed estate recoveries can translate into millions of dollars across a national portfolio.

Longer Loan Terms Increase the Likelihood of Deceased Accounts

Longer repayment periods naturally increase the probability that lenders will encounter borrower deaths before loan maturity. Industry research from Experian Automotive continues to show extended loan terms remaining common across both new and used vehicle financing. What once may have been an uncommon servicing event is becoming increasingly routine for large lending portfolios.

Turn Current Compliance Challenges into Future Revenue Opportunities

Recovering balances from an estate is a specialized process that requires accurate deceased identification, timely estate discovery, and a compliant approach to working with survivors and estate representatives. Many lenders still rely on reactive processes, only researching a borrower’s status after missed payments, repossession activity, or charge-off events occur. While reactive methods may address immediate collection needs, they can cause lenders to miss valuable opportunities to file claims against eligible estates.

A proactive decedent account recovery approach allows lenders to:

  • Identify deceased borrowers earlier in the account lifecycle

  • Determine whether a probate estate exists

  • Evaluate potential recovery opportunities before deadlines expire

  • Reduce unnecessary write-offs associated with missed estate claims

  • Create a more consistent and compliant experience for surviving family members

Find and Recover What Would Be Lost Revenue from Estates with DCM Services!

Have you noticed these issues creeping up on your organization? Did we uncover a blind spot? Did you just run the numbers and are now panicking? We have solutions that can get you on track to close this revenue leak for good by collecting significantly more of these balances without increasing your workforce or operational overhead! In fact, one client recently reported a 7,500% ROI after partnering with us. Contact us today and we’ll tailor a solution to your organization!

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FAQ

What is decedent account recovery?

Decedent account recovery is the process of identifying deceased borrowers, locating estate or probate information, and pursuing compliant recovery opportunities before accounts become unrecoverable.

Why is early deceased borrower identification important?

Early identification allows lenders to determine whether probate exists, identify authorized representatives, and pursue recovery opportunities before important filing deadlines expire.

Can deceased account recovery reduce charge-offs?

Yes. Earlier identification often creates additional opportunities to recover balances through estates, reducing unnecessary write-offs and improving portfolio performance.

How does decedent account recovery support compliance?

Specialized workflows help ensure communications occur with appropriate parties, documentation is maintained properly, and recovery efforts align with applicable estate and probate requirements.

How often should lenders screen portfolios for deceased borrowers?

Best practices vary by institution, but many lenders benefit from ongoing or regularly scheduled monitoring rather than relying solely on customer notification or returned mail.

What industries use decedent account recovery services?

While commonly used by auto lenders, decedent account recovery solutions are also valuable for a range of financial institutions, healthcare organizations, government agencies, utilities, telecommunications providers, and other organizations managing consumer accounts.

Decedent Account Recovery: The Compliance Risk and Revenue Leak Hiding in Plain Sight

Across collections, consumer lending, financial services, and healthcare, unresolved decedent accounts are treated as a rare exception. The data says otherwise.

Every collections floor, loan servicing team, and patient billing department has the same file drawer nobody wants to open: accounts belonging to people who have passed away. Most organizations treat it as a rare interruption to the otherwise normal workday, handled ad hoc whenever it surfaces. But across credit card portfolios, auto and mortgage lending, credit unions, utilities, and healthcare revenue cycle management, decedent accounts are constant, and they compound daily in ways most servicing infrastructure was never built to see. The account continues being a liability when the accountholder dies, it just moves from being a delinquency problem into being a compliance and probate problem.

At a Glance

  • Decedent accounts carry a dual exposure: compliance risk (FDCPA, Regulation X, state licensing) and quietly unrecovered revenue.

  • Probated estates liquidate, on average, seven times more than non-probated estate inventories, yet most portfolios have no systematic way to tell which decedent accounts are even probated.

  • The gap usually isn't negligence. It's the absence of a dedicated process for date-of-death verification and nationwide probate matching.

  • The fix is treating decedent account recovery as its own discipline, not a subset of standard collections or billing.

Why Decedent Accounts Break the Standard Collections Playbook

Standard collections and servicing workflows are built around delinquency signals: a missed payment, a returned statement, a non-response to outreach. Death doesn't reliably trip any of those signals in time. A family member may not notify a servicer for weeks. A card issuer may not learn of a cardholder's death until a dispute surfaces months later. An auto lender may not realize a borrower has died until someone else is already driving the financed vehicle, which adds fraud exposure to a deficiency balance nobody flagged.

The compliance rules governing this window are in a rulebook of their own. Once a collector has knowledge that an account belongs to a deceased consumer, outreach has to shift to the estate representative or successor in interest, and both tone and documentation carry more reputational weight than a routine delinquency letter. Mortgage servicers answer to Regulation X requirements. Credit unions and banks operate under state licensing regimes, such as the Nationwide Multistate Licensing System, that can vary enough that a fully compliant process in one state creates exposure in another.

The Revenue Case Nobody's Modeling

Just from an economic standpoint, each day a decedent account goes unidentified is a day closer to a balance getting written off that a probate estate would otherwise have paid. That difference in days has everything to do with whether anyone identified the estate, filed a timely claim, and engaged the executor before the estate closed. In auto lending, that discipline has produced more than $10 million in recoveries for lenders who treat decedent accounts as an active recovery channel rather than a write-off category. Utilities and credit unions describe the same pattern in different words: balances that fall outside traditional collections processes aren't gone, they're unclaimed. The revenue was recoverable all along; what was missing was a mechanism to catch it before the window closed.

One Blind Spot, Four Industries, Different Stakes

The underlying problem is identical everywhere: an account tied to someone who has died, sitting outside the systems built to catch delinquency. The shape of the exposure changes by sector — and so does what's actually on the line.

  • Collections & consumer finance — Risk trigger: cardholder death goes unreported for weeks or months. Compliance layer: FDCPA successor-communication requirements. At stake: complaints, regulatory inquiries, avoidable write-offs.

  • Auto lending — Risk trigger: borrower dies; vehicle stays in use or insured under someone else. Compliance layer: state licensing, fraud exposure. At stake: deficiency balances, unauthorized use, asset depreciation.

  • Credit unions & banking — Risk trigger: older member base; first- and junior-lien mortgage exposure. Compliance layer: Reg X, NCUA member-treatment expectations. At stake: member trust, uncollected junior-lien balances.

  • Healthcare revenue cycle — Risk trigger: patient balance remains open after death. Compliance layer: sensitive billing standards, state-specific rules. At stake: reputational risk, uncollected patient revenue.

Credit unions feel this acutely: their members skew older than typical bank customers, making decedent accounts proportionally more common and more consequential for relationship-based institutions. Healthcare providers feel it at the most sensitive intersection of all — grieving families, HIPAA-adjacent sensitivities, and the reputational cost of appearing aggressive at the worst possible moment. Different stakes, same root cause.

Treating Decedent Account Recovery as Its Own Discipline

The fix isn't a harsher version of collections. It's a different workflow, built around three capabilities most standard servicing and billing stacks don't have on their own:

  1. Continuous date-of-death verification against a multi-sourced database, so accounts get flagged as they occur rather than in a periodic batch scrub.

  2. Nationwide probate matching, so decedent accounts are checked against actual court filings instead of assumed open or closed — including second-mortgage and junior-lien cases where a narrow window is the only realistic path to recovery.

  3. A single, well-briefed point of contact with the estate representative or executor, built for accuracy and dignity rather than speed and volume.

Done well, this is a compliant, well-documented recovery channel that protects brand and community trust while recovering what's actually owed, from the party actually responsible for owing it.

The Silent Line Item Doesn't Have to Stay Silent

Decedent account recovery will keep growing as a share of every serviced portfolio. Organizations that keep treating it as an exception will keep writing off recoverable revenue and absorbing avoidable compliance risk. Organizations that build a real decedent account recovery discipline turn the same accounts into a compliant, revenue-positive, trust-preserving process instead. The balance sheet's quietest line item is also one of its most fixable.

Start Recovering Lost Revenue Today!

DCM Services can help your organization find new revenue while staying compliant and not increasing your company’s headcount. Contact Us today and we’ll create your tailored recovery plan!


Frequently Asked Questions

What is decedent account recovery?
Decedent account recovery is the process of identifying, verifying, and collecting on accounts belonging to customers, cardholders, borrowers, or patients who have died. This is typically done by confirming date of death, matching the account to any probate estate filing, and engaging the estate's executor or representative rather than the deceased individual directly.

Does the FDCPA apply to decedent accounts?
Yes, though the rules of engagement change. Once a creditor or collector has actual knowledge that an account belongs to a deceased consumer, communication needs to be directed to the estate representative, executor, or successor in interest, and both the tone and documentation of that outreach carry additional compliance and reputational weight.

Why do probated estates recover more than non-probated estates?
Probate creates a court-supervised process for identifying and paying valid claims against an estate. Without a probate filing, there's often no formal mechanism compelling payment of a decedent's outstanding balance. This is a major reason why probated estates liquidate, on average, seven times more than non-probated estate inventories.

Which industries are most exposed to decedent account risk?
Any organization managing recurring consumer accounts carries some exposure, but the risk concentrates in credit card issuers, credit unions, auto lenders, mortgage servicers, utility providers, and healthcare organizations… really anywhere accountholders skew older or carry long-term financed or recurring balances.

How is decedent account recovery different from standard debt collection?
Standard collections responds to delinquency signals like missed payments. Decedent account recovery responds to a death trigger that most servicing and billing systems don't reliably detect on their own, and it requires specialized compliance handling, probate matching, and a more sensitive communication approach than typical delinquency outreach.

When Patients Pass – The Compliance Issue Every Provider Needs to Know

Nearly a decade ago, DCM Services conducted an informal survey of more than 100 health systems and other providers in an effort to understand current practices in the management of accounts for deceased patients.