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I was on the CFPB’s Consumer Advisory Board. Until Mulvaney fired me

posted on 2018-06-12 by Arjan Schütte
Editor’s note: A version of this first appeared on Medium. I was fired from the Consumer Financial Protection Board’s Consumer Advisory Board last week, along with all of its other members. Why? Because the acting head of the bureau, Mick Mulvaney, appears intent on running the consumer protection bureau into the ground while claiming a lack of “global perspective” and wanting a “fresh start.” Never mind that this board has been the most diverse it has ever been — split about evenly between consumer advocates and business people (with some academics thrown in for good measurement). If Mr. Mulvaney was concerned the board was only wild-eyed consumer protection activists, he didn’t appear to notice executives from industry giants Citi, Discover, FICO, Mastercard and PNC. Or if he really cared about private sector innovation, as he claims, he missed the presence of fintech legend Max Levchin, TrueAccord’s Ohad Samet, NerdWallet’s Tim Chen, Oportun’s Raul Vazquez (both of the latter being Core portfolio companies, for disclosure) and myself. This mass firing is the latest in a string of actions meant to kill a regulatory body that was formed in response to the most devastating consumer financial abuse in nearly a century. Mr. Mulvaney, famous for having called the bureau a “sick, sad joke” before taking its helm, was installed as a cynical gesture by a president who knew the bureau was too popular to dismantle. Mr. Mulvaney has all but kicked the life out of the bureau through a series of navel gazing exercises and a moratorium on all (but Wells Fargo’s) enforcement of legal consumer protections. Acting Consumer Financial Protection Bureau Director Mick Mulvaney's decision to fire the bureau's consumer advisory board is just the latest example that underscores his desire to kill an important regulatory body. Bloomberg News “Good riddance,” you say? I’d ask you to think again. Yes, our financial regulatory system is a messy patchwork of state and federal agencies. Yes, the industry is spending way too much on compliance, shuffling way too much paperwork. Yes, I think the CFPB overused its stick relative to its carrots in the past. Instead, we should make a long-term, concerted effort to modernize our regulatory infrastructure (taking inspiration from the United Kingdom and Singapore). But consider the alternative: every rule in place today is a response to incredible harm done to hardworking Americans by greedy, unscrupulous, short-sighted and sometimes outright criminal actors in finance. The CFPB, in several short years, has collected more than $12 billion in penalties for 29 million Americans who were sold misleading products or services. As a profit seeking capitalist who invests in high-growth fintech startups (like Ripple, Mosaic, Oportun and more than 30 others), I believe in guard rails, in rules, in regulation. And I believe the prudential regulators’ primary responsibility of safety and soundness of our financial system does not adequately protect consumers. And I believe financial products are sufficiently complex and materially impactful on people’s lives and livelihoods that having a consumer watchdog is entirely warranted — even if it is a pain the ass, a cost to the system, and a drag on innovation. The stakes are just too damn high, for each household and for our country. So, yeah, I’m sad we were fired for no good reason. It was a genuine honor to serve on the Consumer Advisory Board for more than a year. But that’s completely immaterial to the systemic irresponsibility I believe Mr. Mulvaney is exhibiting to his duty to protect everyday Americans from harm. Further, wildly oscillating regulatory entities cost the industry by introducing even greater uncertainty. And what is perhaps to me the most annoying: Even a conservative, limited-regulation leadership can express itself in smart governance and shifting priorities; it does not need to resort to spreading organizational cancer. Arjan Schütte Arjan Schütte is the founder and a managing partner of Core Innovation Capital, a leading venture capital fund investing in financial services companies that empower everyday Americans.


All In One Pricing For Repossession Services Offers Potential Benefits But…..

posted on 2018-06-05 by Thee Chang

Over the past 12-18 months, there has been a real increase in interest by lenders around the idea of establishing “all in one pricing” (AiO) with their repossession forwarders.Most of this interest has been spurred by concerns expressed by the CFPB regarding ancillary fees as well as a desire by lenders to simplify the invoicing/payment process.   AiO can, indeed, offer benefits in these areas.However, as many lenders have come to understand, it must be approached very carefully and requires fairly deep analytics to gain a clear view of where the pricing should fall.While many lenders have been examining the strategy, at this point, very few have adopted it as they have come to realize they simply don’t have the data points necessary to gain a solid understanding.The remainder of this article will examine the key issues surrounding AiO pricing with the aim of giving you a better understanding of the dynamics that come into play.   What Is AiO Pricing?   Perhaps the answer is obvious, but we have found that different lenders do have different views.In its purest form, AiO pricing is a single flat fee that covers the cost of the repossession and all ancillary services that might come into play to complete the processes required by the specific case.This may include:   ·Key cutting ·Personal property ·Storage ·Redemption ·Use of flatbeds ·Transportation to auction   It would be great if the full cost of these services could just be added to the cost of every repossession.However, since all, some or none of these services may come into a play on a given case, simply adding the full fee to each obviously would result in an AiO fee that would be ridiculously high.   So, the challenge lies in understanding the utilization factors relating to the various ancillary services possibilities.Unfortunately, the utilization factors can vary tremendously from portfolio to portfolio and, therefore, detailed analytics are required to come up with a fee that makes sense for both your customer and your vendor partner.   Let’s take a look at some of these variables and how they can impact the pricing model.   Key Cutting   As we all know, sometimes a key is obtained when a car is recovered and many times one is not.To determine a key cost factor that can be applied to every repossession, you have to make an assumption about what % of recoveries will require a key.This is data that we are able to track in our proprietary database and I can tell you we see a wide variation, ranging from 2-3% to as much as 10% where keys have been provided.   Another very significant factor is the mix of the types of keys required.Again, it can be very portfolio specific.For instance, we have one large captive lender client that was an early leader in the deployment of proximity keys which are very expensive.The average key cost is off the chart.Conversely, we have title lending clients where exactly the opposite is true.The chart below summarizes the impact both can have on the AiO price.  

Captive Lender

Title Lender

% of Vehicles Keys Must Be Cut

10%

10%

Avg Key Cost (based on mix)

$235

$144

AiO Cost Factor

$24

$13

Your institutions’ policy regarding keys can also have a major impact.Some lenders want operational keys available on all cars prior to transport.Others only want keys cut if required to access the vehicle for personal property determination.Several considerations….and we have only covered keys!

Redemption Fees

Pricing for the costs related to the redemption of the vehicle by the customer is one of the trickiest aspect of AiO pricing.The first hurdle is to understand the average redemption rate on the portfolio.To predict the variable with any confidence/accuracy, one must have at least six (preferably 12) months of history tracking the issue.Not only do redemption rates vary significantly by lender, but they also vary significantly by portfolio within the lender.For instance, a post charge off skip portfolio will have a much lower redemption rate than a 1st placement pre-charge off portfolio.

To put the issue in context, we have one lender whose 1st placement business redeems at a 24% rate and another that redeems at a 42% rate.Assuming that the agent will be limited to a maximum total fee of $150 per actual redemption, the impact on the AiO rate would be:

AiO Cost Factor

Port A (42%)

Port B (24%)

$63

$36

The other very important component of the redemption related costs is the amount the agents are allowed to charge the lender in redemption situations.Any redemption has a potential combination of personal property, administrative and storage related cost that the agent does expect to invoice.Historically, these costs have varied by region and even by agents operating in the same region.However, for an AiO approach to work, these fees must be standardized across all forwarders/agents.The approach to doing so is all over the board.We will leave that for another article.

Personal Property – No Redemption

In many cases, a car is not redeemed but the customer does want to retrieve personal property.Due to CFPB concerns, most lenders do not want the agent collecting any personal property related fees from the customer.However, it properly account for these fees in the AiO model, one must make assumptions on what percent of recovered vehicles will involve retrieval of personal property.Again, it varies meaningfully by portfolio.

Storage

Excess storage fees must also be accounted for in the model. Most repossession come with a certain amount of free storage, but what happens when that is exceeded?The AiO model must anticipate that possibility and assign a cost for it.Again, that can vary significantly by portfolio.We work with one lender that generally moves cars off the lot to transport within 4-5 days and another that averages almost 20 days.

Clearly the AiO pricing model has many moving parts.If you want the right price and you want to feel confident that your vendors will be able to live with that price for a reasonable period of time, you will need to be able to provide very solid data on your portfolio.If you are unable to do so, our recommendation is to have a very transparent process with your vendors in which all assumptions are provided along with the resulting pricing model.With that in place, all parties can monitor the actual performance and agree to make adjustments accordingly.




10 Tactics and Advantages Debtors Have When You File Suit for Debt Recovery

posted on 2018-03-12 by Dennis Falletti

 

It is well-known that litigation costs and business failures have been rising. Today, bankruptcies are at an all-time high, but even more startling is the increase in businesses that simply lock their doors and walk away. Adding to the problem are companies that were operating in the black, but now show too much red ink. The results of this is an increase in companies that are paying their bills slower, asking for extended payment plans, paying their preferred or secured vendors first, then picking and choosing who to pay and who not to pay. Statistics show that the average credit ratings of companies are declining and their “will to pay” is keeping pace. Adding to their burden is an aggressive move by the IRS and state authorities through increased audits resulting in (not anticipated) tax due with tax liens placed upon their business. Adding to the credit grantor’s misery is the fact that debtors are more educated today about who to pay, when to pay and who not to pay at all. This trend can be tracked to the source, which is the public media, social, advice from their attorneys or peer-based experiences. Too often we see debtor companies invite and use litigation as a means to an end. Debtor companies know that if litigation action is taken against them, they have a number of options and tactics they can use to their advantage.

What are those advantages?

1. Time

Debtors and their attorneys know that when suit is filed, they can use various stalling tactics allowed by the court systems. Debtors can buy as much as 18 months or more before they seriously are forced to make a payment decision. Their tactics include the following: avoiding service disputes that need validated continuances motions for discovery demanding witnesses no show at trial resulting in default judgments with no revenue recovery pursuit These tactics, in many cases, are intended to test your litigation policy and resolve allowing you to make errors that they can use to their advantage.

2. Money

Many debtors know, since they are in business themselves that companies set a suit threshold before they will consider filing suit based on what the creditor believes is a balance size that justifies litigation. Not knowing what it is but having knowledge of its existence gives them the advantage of waiting out collection agency phone calls, letters and threats of potential litigation and will wait to see if and when it happens. Depending on the balance, many know for sure that suit will not be forthcoming so the bill remains unpaid.

3. Poor credit rating

Debtors who have a poor credit rating have the advantage. What more can you do to me? So why should I pay? The problem here, if you are an unsecured creditor, is that they will pay their secured creditors on time and neglect your bill opting many times to simply find and switch to a competitor who will grant them credit or operate C.O.D. when needed. They have no sense of urgency.

4. Lack of a good credit risk management procedures

Nothing intimidates a potential debtor more than complete and thorough credit risk investigation prior to adding them as a customer. It is a physiological fact that impacts their thought process from the beginning. Having a weak policy or one that allows a company with poor predictive pay patterns to order on terms sends a message that advantage can be taken, at will, if needed.

5. Sympathetic court system

Let’s face it - the court system is overworked, crowded and has become more pro-debtor. Cases for debt payment are being pushed out farther into the future by judges due to defendant requests for more time as a means to advance more pressing cases.

6. Counter suits

This tactic is very effective simply because it elevates the plaintiff’s costs, time and interjects uncertainty in decisions by the plaintiff and forces the plaintiff to consider their return on investment. It forces credit granters to ask themselves, what will be the cost to pursue the debt and defend against a counter suit? What are the odds of the plaintiff winning? What are the odds of the defendant winning? What will I gain at the end? Is the cost simply worth the time and return? In some cases the answer is yes, but in other cases, no.

7. Witnesses and depositions

This tactic is a very effective method of getting the case pulled at the plaintiff’s request due to the cost involved and time constraints on under staffed departments. Court systems are stopping the practice of allowing phone witness depositions and forcing the plaintiffs to produce a specific witness in person, not allowing your collection agency to represent you or to use anyone available at your company. Defendants and their attorneys subpoena specific people as a “must” attend. If the plaintiff sends a witness, many times the defendant’s attorney will ask for a continuance forcing the witness and company to spend more money to the point that the return on investment will not be worth the effort.

8. Settlement on the courthouse steps

Too many times we have seen the litigation process advance, costing the plaintiff substantial time and money only to result in a settlement at the last minute, virtually within the courthouse just prior to hearing the case. Many of these settlements accepted are the same amount or slightly higher than what was offered in months previous during the collection phase of recovery. The advantage for the defendant is that they have successfully bought the time to plan the repayment on their terms. The disadvantage to the plaintiff is that they have spent more money and time through litigation costs and increased attorney contingency fees for obtaining the settlement.

9. Judgments

When litigation is successful, the advantage to the defendant is that in many cases they can get a court ordered payment plan better than what was offered during the collection phase of the process. An additional advantage is that they will not stick with that plan and the Plaintiff and their attorney must keep spending time and money to pressure the defendant to make the scheduled payments.

10. Default judgments

Debtors know, especially if they have a poor credit rating, that a default judgment is nothing more than a legal document stating they owe the money. Something you and they already know. The advantage for the defendant is that judgment enforcement is costly and many plaintiffs will not pursue the enforcement due to the additional costs. It is reported by many of our clients that their chosen attorney is remiss in pursuing enforcement because their client will not pay more for the enforcement and they will not want to incur cost out of pocket to do so. They simply decide to pursue better case options. In this scenario the defendant gets away without paying. Today more than ever, a change in the status quo of litigation policy and procedures is needed. [ Related:When is Litigation the Answer? ]




How Much Bad Debt Do You Really Have?

posted on 2018-03-12 by Dennis Falletti

 

It seems like a straightforward enough question. Any receivables manager should be able to answer it with a quick glance at a report or two. Unfortunately, the number at the bottom of the page is a lot like the tip of the iceberg. It’s what you don’t yet see that may end up doing the most damage.

Tightening up requirements

You’d be hard pressed to find a company not taking a long hard look at their credit and collection policies, and for obvious reasons. Shorter terms, lower balances, additional and more thorough credit references are just a few areas we’ve all tightened up on the front end. Working accounts sooner, with a more uniform and accelerated escalation process is becoming a new doctrine for collection managers on the back end. So if we’ve tightened up requirements on the front end, and we’ve taken in some slack we previously extended to our slow payers, where should we look now? Even the most diligent credit manager or analyst would be hard pressed to consistently and accurately read the future. Your best customer two years ago could very well be succumbing to the same financial hardships so many others have. And, unlike the one time, hit-and-run customer, your instincts will likely be to extend some leniency their way if they do slide a little. Unfortunately, the slide could be more rapid than anyone expects. So instead of relying on a credit application from ten years ago and a previously solid payment history, why not take an additional step to protect your interests?

Annual credit risk assessments

An annual credit risk assessment of your active customers can provide insight and allow you to make more informed and appropriate decisions based on their current financial health. Some clients run a complete portfolio analysis for all customers annually and even run their “B” and “C” tiers of customers quarterly. On more than one occasion, the trending information they’ve received has allowed them to probe a bit further before green lighting a large order. And in some cases, the order size or terms can now be adjusted to reflect the updated potential risk factors. Accessing the various databases and information needed to come up with useful results would likely be cost prohibitive for most companies to do themselves. However, in some cases, the cost of programs such as these can be zero. More often than not, the results of a credit risk assessment hold at least a surprise or two.




When Should You File Suit?

posted on 2018-03-12 by Don Leviton

 

A lawsuit is generally the last option that should be chosen in trying to resolve a dispute. This question of whether to file the lawsuit enters the mind of many people who are upset with a bad product or service, or breach of an agreement. In order to answer this question and make a decision, one must consider the following factors:

Potential Recovery

Calculation of expected recovery, if the lawsuit is won, is based on the best case and worst case scenarios. Expectations may not be realized. Not all damages may be recoverable. In case of breach of contract, the aggrieved party’s emotional distress is not compensated; loss of income, plus time spent, while involved with a claim or suit is not compensated; interest may or may not be recoverable. In most instances interest is only recoverable if provided for in a credit agreement or contract. Your attorney’s fees are probably not recoverable unless provided for in the credit application or contract. The amount of actual recovery in a lawsuit is unpredictable.

Attorney Fees and Expenses

Legal fees may be based on an hourly rate or contingency fee basis. An hourly rate depends on a lawyer’s experience, relationship with a client, desire to have repeat business, or volume of client’s business being given to that lawyer. Lawyers charge for each minute of their time spent on the case. Billable time can include, every telephone call to and from a client or any other party related to the client’s matter; meetings, legal research, writing of letters and briefs, time in court (which may be charged at a higher rate than for the office work), preparing legal documents, travel time or depositions (interrogations of parties and witnesses) are recorded and then billed to clients. Expenses connected with the case may reach such a level that further litigation may become counterproductive. Typical file expenses may include fees paid to the court for filing a suit; the sheriff for serving a party with a complaint and summons; a private process server or private investigator for finding a defendant or ascertaining a party’s criminal or financial background; interpreters for translation of documents or interpreting the testimony of a witness or a party speaking a foreign language; experts for giving professional opinions; copying of documents and photos, cameramen and photographers for videotaping and picture taking; court reporters for their attendance time and preparation of transcripts of the proceedings; and attorneys for transportation and lodging (for out of town meetings). On the other hand, a client does not incur such monthly charges if an attorney agrees to take the case on a contingency fee basis. Contingency fee means that an attorney is participating in the claim recovery, if any, on an agreed percentage. As a rule, such percentage fluctuates between 20% and 50% of the amount of recovery. An attorney may advance costs and expenses of litigation to be repaid upon settlement or adjudication or a claim. However, a client remains ultimately responsible for expenses under any of the above-discussed methods of payment.

Alternative Dispute Resolution (ADR)

There are many organizations and individuals who are willing to serve as a mediator, counselor, or a judge in a private or out-of-court proceeding. Sometimes it is less costly and faster to resolve any dispute through such intermediaries than to litigate in courts. Mediation involves a semi-formal or informal process of introducing evidence by parties. Parties may bring witnesses or documents to support their views and may hire attorneys to represent their interests at the hearings. Arbitration may be accomplished through government or private organizations, such as American Arbitration Association (AAA), JAMS, Endispute, and many others. Former judges or experienced attorneys hear the evidence and make binding decisions. The rules of the AAA or other adjudicating bodies are different and less restrictive than the rules of evidence adhered to by the courts. [ Related: From the Desk of Attorney Don Leviton: Resolving A/R Disputes ]

Collection on Judgment

After a long and victorious litigation, a winning party secures a judgment from an adjudicating tribunal. This piece of paper may or may not materialize into actual funds being transferred to the winner. Collection on a judgment is a separate legal process. Sometimes one may never recover the award if a judgment-debtor declares bankruptcy which would isolate that party from claims of creditors, including the judgment-winner or judgment-creditor; a judgment debtor dissolves its corporation and, adding insult to injury, opens a new company under another name; all assets of a judgment-debtor are under other parties’ names (relatives, friends, corporations, or business associates) and, therefore, that party becomes judgment-proof.

Piercing the Corporate Veil

If a business takes the protection of a corporation, LLC, in some instances the individual owners may be ultimately liable for their corporate debts, if it can be proved that the corporation or LLC is just a shell for the individual owners.This can happen where the owner uses the same checking account for personal and corporate debts, or there is no adherence to corporate formality.Most states require that corporations, LLC etc, follow certain rules such as holding annual meetings, keeping corporate minutes, resolutions, etc.This process of piercing the corporate veil is possible, and must it must be done in the courts. It can be a time consuming and expensive process.

Length of Litigation

Litigation is a slow moving process which may take months and, in most cases, years before reaching the trial stage. After filing a complaint there can be many delays caused by the judicial system and frustrating the parties. There are many reasons for delaying the proceedings, including an attorney that continually asks for continuance of a deposition or trial because of the attorney’s family emergencies or conflict of schedule; a party which has to be deposed or answer interrogatories is out of town; an expert witness is unavailable on the scheduled deposition or trial date; the file was recently transferred to another attorney who had no chance to prepare for trial; the suit was filed in a wrong venue and, must be transferred to another court; service on the defendant was improper and, thus, must be properly repeated again; a judge assigned to handle the case has left for vacation, or is sick, or temporarily transferred to another court, or is still busy with the preceding trials; a new defendant has been added and, consequently, time is needed to conduct written and oral discovery associated with that defendant.

Opposition

An opposing party’s financial, intellectual and legal wherewithal may affect a decision to initiate litigation. The opposing party’s ability to sustain a prolonged judicial process, the quality of their attorneys, and legal defenses may either encourage or stop the filing of suit.

Principle

Often people desire to punish an opposing party or change the law and, therefore, want no recovery. There are political, moral or social causes which prompt such a decision.

Time Consumption

Litigation is time consuming for the participants. A party must appear at depositions and at a trial. The trial may continue for at least a few days or even weeks. Preparation for a deposition and the deposition itself can take one or more business days. Mandatory arbitration, which in some states is part of a court-based judicial system, also will take about a day. Consultations and meetings with attorneys, as well as answering interrogatories (opposing party’s questions) and requests for production of documents, take many hours of business time. Loss of business time is translated into a loss of income.

Stress

Besides court appearances and testifying under oath at depositions, arbitration and trial, each participant is thinking and worrying about the case outcome at all times. Such incessant consumption of energy and emotional involvement may increase the daily stress of a person. Such psychological and mental drain takes a toll over the course of time.

Lawyers

Trust in the attorney’s abilities and rapport with that attorney are essential for cooperation, decision making and communication efforts. Experience in litigation of the matters at issue is important. One may present his own case in any court but the judges usually resent this “pro se” representation because “pro se” litigants are not familiar with the court and evidence admission rules. In small claims courts where the amount of recovery does not exceed a statutory limit set up by the legislature, for example $2,500 or $5,000, a plaintiff may not need an attorney.

Counterclaims

A complaint filed in court may trigger a counterclaim by a defendant against the plaintiff for another act related to the complaint. For example: a complaint by a company for payment for goods sold and delivered may trigger a client’s counterclaim or defense of warranty or defective goods. That is why a review of one’s own vulnerable points and background is needed in order to ascertain the level of risk in that regard. Any past wrongdoing may come to light in the court proceedings.

Loss of Suit

In case a lawsuit is lost, the losing party will still have to pay legal fees to his own legal counsel, unless there was a contingency fee agreement, plus file expenses, and the court costs of the opposing party. If a contract provides for payment of attorney’s fees of the prevailing party, then these fees also must be paid by the losing party. Name, reputation and prestige may also be affected by that legal loss. Disclosure of trade secrets may be forced upon a party by the court.

Administrative Remedies

Besides the court system, there are many other tribunals which may help an aggrieved party. In general, any problem may be addressed to the governmental agency responsible for or regulating that area of conflict. For example: the State’s Office of the Attorney General may help victims of violent crimes, antitrust violations, consumer fraud by businesses and individuals, etc.; a state’s Department of Insurance may be asked to secure payment from insurance companies vexatiously and frivolously delaying payment; and the Department of Labor may impose sanctions on employers in their disputes with employees.

Appeals

A party may appeal the trial court’s judgment to a Court of Appeals which may affirm, or remand the case back to the trial court for further proceedings, or to reverse a judgment. An appeal process may take a years. In case of reversal with remand, a trial can repeated. Costs will be increased proportionally. In case the trial court decision or judgment is affirmed, a losing party may try to appeal to the State or the U.S. Supreme Court but the chances of a commercial case being heard by the Supreme Court are very low. A prevailing party is accumulating interest on the trial court award. That interest is set by a state statute. In Illinois, for example, judgments earn annual interest at nine percent. Knowing all the deficiencies and advantages of the judicial system and practical aspects of the litigation process should help any person or legal entity to make a decision to settle, arbitrate, or adjudicate any claim. Sometimes a letter from an attorney or third party mediator may bring the parties to an amicable resolution of a dispute. It is not justice, but the fair and economic compromise of the parties’ positions that is the goal of such resolution. Information in this article is provided as a matter of information and education only. It is not intended to provide legal advice or counsel. Do not take action in specific cases without full knowledge of the facts, and competent legal advice from your attorney.





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