Compliance and a Forward View for the Repossession Industry
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Compliance and a Forward View
for the Repossession Industry
Presented by:Paul Kulas
Head Belle Ringer, BellesLink.com
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Originally Presented by Paul Kulas at NARS, April 2013
• Owner and Head Bell Ringer at BellesLink.com• Owner of Belles Camp Communications• Developed key communications services for the
Repossession Industry dating back to 1991
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Compliance is No Longer an Option – It’s Required
• CFPB – where it is today• Where we think CFPB is heading
– Why repossession operations should consider making changes
– Why these changes will benefit you – even if I’m wrong
• Techniques for skip tracing that are fully compliant• Observations, present and future vision for
Repossession Industry
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…financial institutions under Bureau supervision may be held responsible for the actions of the companies with which
they contract. The Bureau will take a close look at service providers’
interactions with consumers. It will hold all appropriate companies accountable
when legal violations occur.source: CFPB Bulletin - April 2012
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Compliance
• No standard definition• Widespread opinions• Everybody’s talking• An investigation will be broad ranging and
cover every aspect of lending operations*– Loan servicing – Repossessions
*source: Dealer Business Journal – June 2012
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Consumer Finance Protection Bureau
• Title X of Dodd-Frank Wall Street Reform and Consumer Protect Act
• Comprehensive change in financial regulation• Extended rule making authority to ‘larger non-bank
participants• Indirect supervisory authority
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Consumer Financial Protection Bureau to Hold Financial Institutions
and Their Service Providers Accountable
“The Bureau will take a close look at service providers’ interactions with consumers. It will hold all appropriate companies accountable when legal violations occur. “
CFPB Director Richard Cordray
April 10, 2010 CFPB Bulletin
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Where We Think CFPB is Heading
•Indicators are CFPB will grow – therefore:– Every communication (calls, texts ,emails) should
be linked to a case– Each database lookup should be linked to a case– Every communication and all database lookups
need to be in one place, available with one mouse click
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Our Qualified Intuition
•Belles Camp has 22 years of experience– Key innovation and communications techniques for the
repossession industry (trap line, blind line, real-time caller ID, etc. dating back to 1991
– Remember the slides? Solid evidence there– Predicted in 2007 the amendment to the Communications
Act (making spoofing illegal) would become law. Law signed 12/22/2010
– Saw CFPB coming. Software and hardware development began early 2010
– BellesLink introduced July 15, 2013 - leading the way again
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Repossession Operations – Today
• Information doesn't flow between all the channels in a repossession
• "Quit calling me!" - way too complicated • Clients are concerned about risk, primarily due
to the fact that everyone isn’t connected
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Changes You Should Consider
1.Build your business with the client in mind2.Link every communication (call, text, email)
and database search to a case3.Everyone involved should be connected,
information updated in real-time1. "Quit calling me!"? Should be one click
4.The cloud is ready – it’s not hype
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Compliant Communications Techniques
• Local Numbers and texting– Local Numbers
– Dramatically improves contact rates (incoming and outgoing calls– Reviewed and approved by Chase Auto Finance*
– Texting• Important technique; essential to every skip trace• Becoming more popular than phone calls• 95% of texts are read within 5 minutes• Wells Fargo* reviewed and approved
• Toll Free numbers still valuable– when used with local numbers
*not meant as an endorsement
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What About Deception?
• Local/toll free numbers, text messaging are not deceptive- You lease the number and can be
reached at the number- Chase* and Wells Fargo* have reviewed
and approved.- Fully compliant with Truth in Caller ID Act
of 2009
*not meant as an endorsement
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What Not To Do
• Don’t try to put a square peg into a round hole - i.e., using Google Voice, Ring Central, or burner phones for skip tracing– They’re not designed for what you use them
for – There’s no support– You can’t suggest improvements– At least 10 other reasons
• Net is that you trip over a dollar to pick up a nickel
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Now What?
• Invest in your core competency - and in your client’s business
• Cloud compliance services are the way to go• Repo industry has unique
challenges—choose/support companies that focus on your business– When you call, they get it—they listen and
respond
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BellesLink.com is a fully compliant, cloud-based, virtual communications tool for Automobile Repossessions, Investigations and skip tracing
•Unique.•Affordable.•Valuable.
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Risk/Return on Investment
• Risk:– Letter comes: "You have 15 days to comply with the
following requirements…” Now what?• Return on Investment:– If CFPB goes away, never extends its reach beyond
where it is today, you're way ahead• Linking your communications and database searches to the
case improves day to day operations
• Makes you more marketable to your clients– When the letter comes: you’re ready
• Make or break moment in your business
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Observations, Present and Future vision - Repossession Industry
• Merger (ARA/NFA) great 1st step, long over due• Co-opetition - it works. It’s been around since 1911
http://mayet.som.yale.edu/coopetition/ • Examples of successful co-opetition
– The Auto Industry• GM/Toyota – fuel cells GM/Ford– gas saving transmissions
– Oil/Gas business in Denver, early 80's– Microsoft/Apple– Symantec/McAfee– Google/Firefox– Open Source Software
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Conclusions – Part 1
1. Automobile lending and sales could surpass the boom years - delinquencies can only go up from here - great!
2. CFPB isn't going away1. Well designed website, easy to complain, social media,
they’re hiring…3. Probability high, you’ll be a bigger blip on their
radar 1. Can you afford to ignore the signs?
4. Be proactive—not reactive5. Technology is an asset—not an expense
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Conclusions – Part 2
1. The past is not sustainable. Compliance = cost.- Fees have to increase
2. The way forward:- Industry unity - Power in numbers - Metcalfe’s Law: “The value of a
network increases exponentially with the number of nodes on that network”.
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• "Co-opetition means cooperating to create a bigger business "pie" while competing to divide it up”http://mayet.som.yale.edu/coopetition/
“This is the year of change!”
Les McCook, Executive DirectorAmerican Recovery Association
Embrace Co-opetition
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Thank You!
Paul Kulaswww.bellescamp.compaul@bellescamp.com
970.328.0400
To learn more about BellesLink repossession and investigation software for skip tracing, visit
www.belleslink.comRequest a Free BellesLink demo.
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