The auditor conducted 29 audits in 2014, examining firms for compliance with standards. Their top priorities were risk analysis, communicating standards to clients, and monitoring policies. They created an audit schedule, implemented new procedures, and updated insurance requirements. Milestones included completing recalls and discussions with MCM. Goals for the upcoming year are to help implement the transition to an integrated MCM/ACF audit program. The auditor believes additional training could improve their skills and duties may change once the transition is complete.

1. 2015 Personal Annual Evaluation
What do you consider to be the top three to five priorities of your job as you understand
them?
The auditor position requires analysis and examination of firms in the following areas:
compliance standards, data security reliability, information system protocols, client trust, cash
controls, hiring and training standards. My goal is to communicate, review, monitor and provide
feedback of ACF policies and standards using recognized accounting standards, the Legal Services
Agreement, YGC compliance and Attorney Work. The auditor position requirements include
working with the In‐house Legal Counsel and Director of Legal to propose strategies, monitor
performance and provide corrective actions needed to implement compliance objectives.
The top three priorities would be:
1. Risk analysis: To critically examine and document potential risk in key business functions
that may cause internal or external exposure in the following areas: loss of business
(licensing, Insurance, and Certifications); accounting functions (client trusts, loss of data
and information, hardware and security failures, regulatory risk exposure and vendor
management.
2. Communicate ACF and governmental Standards: To properly inform clients of ACF’s
standards and requirements in all areas of business operations. To communicate A C F
policy requirements provided in the Attorney Work Standards (AWS), Contingency Fee
Agreement and other contractual obligations. To communicate legislative and legal
standards such as (UDDAP, FDCPA, TCPA, Gramm‐Leach Bliley and Fair Lending). To
communicate the guidelines of federal monitoring agencies such as the (FTC, CFPB and
DOT).
3. The Monitoring and testing of policies, standards and procedures: To ensure clients follow
proper standards by requesting client feedback. To test system standards using reports
from YGC, Latitude, CLS, JST and other proprietary systems. To review training standards
by reviewing training modules, test scores, regulatory licensing and mo nito ring call
quality. To verify testing data, data certifications, system redundancies, disaster recovery
plans (DRP), and Incident Response Procedures (IRP).
4. Develop policies, standards, and procedural guidelines: To w o r k w i t h
c o m p l i a n c e t e a m t o development of policies, standards and controls to help
clients meet state, federal and judicial such as the Sixth Circuit Appeals Court
requirements of Stratton v. Portfolio Recovery Associates, LL‐2014. To provide an action
plan for the remediation function or critical failure(s). To help development of collection
and legal best practices. To provide training updates and develop new testing
methodologies (Account Evaluation Spreadsheet, and Call Scoring Methodology).

2. 5. Report activities, reports and results to the Director of Legal, Kevin Bowens and Legal
Director, Waurayne Jordan. To provide the directors with actions plans, remediation
requirements and follow‐up reports. To present the directors with an annual summary
reports, audit calendars and status updates. To provide statements, documents and
reports for outside legal counsel(s) and business partner MCM, Inc.
Competencies: What are your strengths? What makes you successful at your job? Why is ACF a
better place for your having worked here?
My overall strength is the ability to work with firms in a diplomatic manner to resolve
auditing discrepancies. I help firms improve core competencies related to Attorney Works
Standard and the Legal Services Agreement. My success comes from working with good
managers and staff. The Legal Director and In‐house Counsel communicate attainable goals
and provide positive feedback. The In‐house Counsel, Kevin Bowens provides direction
informative critiques. Waurayne Jordan helps to facilitate good working relationships
between the firms and agencies. Others will evaluate my effect on ACF, but I know that ACF
has had a positive effect on me.
Key Results: What did you accomplish as far as Projects completed? Milestones? Events? Hurdles
overcome? Specifically address achievements that have resulted in increased revenues, reduced
expenses, or saved time. How have you had to reinvent your job in light of your department’s
changing needs? How would you grade yourself in terms of work quality, reliability, interpersonal
communication and technical skills? What activities have you participated in over the last review
period in order to develop yourself professionally?
Accomplishments:
 In 2014 the compliance team completed 29 audits, consisting of 12 remotes and 16 on-site.
 Created an Audit Schedule Overview: state of audit review and trending analysis of
firm performance. (In the process of working with MCM’s Kelly MacBeth to improve
trending analysis and expand the audit scope)
 Implemented new audit procedures and methodologies: designed new testing, and
scoring models for account analysis and call monitoring.

3.  Implemented the new legal audit model based on the agency model created by Kevin
Bowens. This model expands the legal audit processes to other areas including:
financial overview, hiring and training, information technology, and vendor
management.
 Updated the insurance folder implemented new insurance requirements based on pre‐
requisites provide by Kevin B.
 Continuing to provide litigation requests for documentation and historical information for
outside counsel.
Milestones, Events, and Hurdles:
Milestones:
 Worked with Waurayne and Kevin B., to complete 2014 recall of ten firms in an attempt
to streamline the legal network.
Events:
 July 2015, the in‐house counsel facilitated discussions with MCM‘s Sr. Corporate
Counsel to discuss the audit processes and discuss data sharing.
Hurdles:
 The expanded audit scope has increased the turn‐around time for audit reports. The prior
process took (2) days to complete the remote/on-site and (3) or (4) days on average to
complete the report. In a normal audit cycle, with an additional (10) days for remediation,
the process from start to finish was (16) days. The new process is (2) days remote/on-site
and (5) to (7) days to complete the report with (10) days for remediation, the process
from start to finish is (19) days. The 72 hour difference isfurther complicated by delays
firms attempting to meet the new audit requirements. I’m still working to overcome this
hurdle.

4.  Working to resolve remediation requirements listed in the Citi audit requiring the auditing
of networks (Trak, Eltman and Investinet). Working to simulate MCM’s network audit
process for ACF audits. Scheduled completion date, end of August.
Achievements/job reinvention:
 All audits in general save the company from lawsuits, embezzlement and regulatory
complaints. The cost is preemptive, though failure to do so could cost the company
tens ofmillions of dollars. The ACF job requirements and guidelines are constantly
evolving. I had to increase my knowledge of case law and regulatory requirements
such as “Fair Lending” and “Meaningful Review”. I’m also more knowledgeable of the
overall operations of the firms (the previous audit was primarily data and financial).
I’m currently working with various department heads including: Sara Wilson,
Compliance Director; John Harvey, IT Director; Heather Clary, Compliance
Management Administrator; Waurayne Jordan, Legal Director and Cassie Boitnott,
Accounting Manager to understand critical areas and incorporate new testing systems
across all business areas. My overall grade for work quality, reliability, and
interpersonal communication skills A‐
Training/Personal development:
 In May, I Attended NARCA (The National Association or Retail Collection Attorneys)
trade conference and signed‐up for the following classes: CFPB an Overview, Navigating
theJudicial Landscape, and Compliance for Small Firms. Met with firms to discuss the
new compliance guidelines and remediation items.
 I’m still working on obtaining my CIA (Certified Internal Auditor) License.
 In July, I signed up for YGC training to better understand reporting and improve the data
relay area of the audit specifically dealing with close codes and status updates. Failing to
upload to YGC has become problematic in recent audits.

5. Opportunities: Where can you improve/become stronger/be more effective? What could you do
to perform your job duties and assigned tasks more efficiently? What initiative will you take in
developing your skills and how to you plan to measure the effectiveness of this initiative? In what
area(s) do you feel you need additional support, structure or direction? Specifically, where can
your supervisor provide you with additional support in terms of acquiring new skills,
strengthening your overall performance, and preparing you for future roles? In what areas would
you like to gain more experience or training?
Improvements needed:
I believe I could use more training in YGC Analytics and Information Technology. I requested YGC
online training however the training is still pending approval.
Perform duties more efficiently:
The audit scope is changing due to regulatory reforms and judicial activism. At this time, an
integrated audit program with MCM is the best scenario to meet the needs and requirements of the
evolving audit landscape.
Skill requests:
August 2015, I requested YGC analytics training to improve reporting and find new audit testing
methodologies.
Additional Support Direction:
Once the ACF, MCM integration is complete the current duties and functions will most likely be phased
out. I am here to aid in the transition.
Support/Direction/Goals:
I received excellent support and direction from my direct report. My supervisor was the catalyst for
beginning the second phase of the audit program. I believe at this time the audit is entering the final
phase of integration.
What are your performance goals for the upcoming year? What are the measurable outcomes so
that we’ll know that you have reached those goals?
My goal is continue to help implement the MCM/ACF audit program and make sure the transition is
seamless as possible.
Other comments/suggestions:
Once the transition process is complete, may cause a phase out in my current duties and
responsibilities. From a business and practical point of view I believe this is the most effective and
efficient path. I appreciate the people at ACF who have made this company a wonderful place to
work. There were times when the position lacked support, however the employee’s and
management team are invaluable.