After analyzing public feedback, as well as information gathered from the five providers of Buy Now, Pay Later (BNPL) products, the Consumer Financial Protection Bureau (CFPB) issued a report, making it clear that the CFPB plans to increase regulation of the BNPL industry.

A form of credit that allows a consumer to split a retail transaction into smaller, interest-free installments and repay over time, the typical BNPL structure divides a $50 to $1,000 purchase into four equal installments. While BNPL credit is interest-free, providers make money by charging fees to both sellers and consumers who don’t pay on time. Launched in the mid-2010s as an alternative form of short-term credit for online retail purchases, BNPL loan usage increased ten-fold during the pandemic.

Among other takeaways from the report, the CFPB found:

• The financial and operational benefits of the interest-free, accessible at your fingertips product over legacy credit products are real and sizeable. According to the CFPB, however, those same benefits may lead to two forms of borrower overextension: loan stacking (the risk of overconsumption from BNPL usage at multiple concurrent lenders) and sustained usage (the risk of long-term BNPL usage causing stress on borrowers’ ability to meet other, non-BNPL financial obligations).

• Consumer reporting companies have been slow to develop credit reporting protocols with respect to BNPL. Mortgage and auto lenders have raised concerns that the growth of BNPL with no associated credit reporting makes it more challenging to know whether a borrower can afford a mortgage or auto loan.

• Credit performance is deteriorating on BNPL loans. In 2020, 2.9% of borrowers “charged off” a BNPL loan, while that number jumped to 3.8% in 2021. Public filings show this upward trend continuing through the first half of 2022.

• BNPL lenders often collect a consumer’s data, as well as deploy models, product features, and marketing campaigns based on that data, to increase the likelihood of incremental sales. The CFPB claims that in addition to the general data harvesting risks, BNPL lenders’ use of consumer data for revenue-generating purposes can potentially increase overextension risks by engendering repeat usage.

Director Chopra also released prepared remarks on the report, acknowledging both the advantages and disadvantages of this new product. “Since taking office, I have directed our staff to identify ways to invite more competition into markets for consumer financial products and services. Buy Now, Pay Later firms are challenging existing players and offering new options to retailers and borrowers.” Director Chopra noted, however, that “[m]any Buy Now, Pay Later lenders are not offering the same clear set of dispute protections that credit card issuers have long been required to offer, which is creating chaos for some consumers when they return their merchandise or encounter other difficulties. Many Buy Now, Pay Later lenders do not offer clear and comparable disclosures of the terms of the loan like other lenders.”

The report and prepared remarks state actions the CFPB intends to take as a follow up to the report. These includes:

• Identifying potential interpretive guidance or rules to issue to ensure that BNPL firms adhere to many of the baseline protections that Congress has already established for credit cards.

• Identifying data surveillance practices that may need to be curtailed — specifically, examining some of the types of demographic, transactional, and behavioral data collected for uses outside of the lending transaction, including for the purpose of sponsored ad placements, sharing with merchants, and developing user-specific discounting practices.

• Identifying options for appropriate and accurate credit reporting on these products.

• Ensuring that BNPL companies are subjected to appropriate supervisory examinations, just like credit card companies.

• Ensuring that the CFPB and the Federal Reserve System methodology used to estimate household debt burden reflects the reality of today’s market.

Director Chopra’s statement noted that “the report prepared by the CFPB staff does not seek to determine whether the rise of the Buy Now, Pay Later market is a positive or negative development. I believe that Buy Now, Pay Later can grow and serve consumers well if we can collectively address some of the gaps I’ve just outlined. If Buy Now, Pay Later lenders incorporate the protections and protocols that we observe in other financial products, this would go a long way to ensure that there is healthy competition where consumers have a baseline level of protections.”

The CFPB’s report denotes the latest action taken to reign in the burgeoning BNPL industry. As we posted here, here, and here, in November 2021, the House Financial Services Committee’s Task Force on Financial Technology held a “Buy Now, Pay More Later? Investigating Risks and Benefits of BNPL and Other Emerging Fintech Cash Flow Products” hearing. For the hearing, the task force invited both consumer advocates and industry tradespeople to address concerns that these products are designed in such a way that the disclosure requirements under the Truth in Lending Act and other credit laws may not apply. Next, in December 2021, the CFPB ordered five BNPL companies to answer a series of questions about the products. In January 2022, the CFPB then issued a notice and request for comment related to the products. In response, the Consumer Bankers Association sent a letter to the CFPB in March 2022, encouraging regulation of the industry.

According to Director Chopra, “As BNPL products continue to grow in popularity and the industry continues to add products and services to meet consumer need, a measured approach to regulation will be necessary to preserve market options and to protect consumers’ interests.”

CHICAGO, Ill. and MOUNTAIN VIEW, Calilf.– Halsted Financial Services places a high value on conversations its agents have with consumers. To maximize that value, Halsted has partnered with Prodigal to utilize Prodigal’s ProNotes solution to humanize each conversation and provide additional context for its agents both before and during calls.  

Prodigal’s ProNotes solution offers agents the ability to easily view 100 percent coverage of previous call notes. By enabling each agent with ProNotes, Halsted’s agents can enter any customer conversation equipped with the full breadth of previous conversations. ProNotes also keeps the conversation focused on the customer exclusively since the agent doesn’t have to hunt around for important context. 

Through those conversations, Halsted can keep track of trends in compliments or complaints. Utilizing ProNotes has provided insight into how consumers feel. With Prodigal’s ProVoice and ProNotes, Halsted is able to learn from the positives and negatives and gain insights about consumers’ sentiments and how its agents can continue to improve.

According to Halsted founder Pran Navanandan, “Over the course of our partnership with Prodigal, we’ve gained a sense for what makes a great conversation for both our agents and our consumers. Now, we can learn from the most successful and positive workflows and talk tracks and add those into Prodigal’s real-time actions tool, ProAssist. ProAssist helps our agents stay completely engaged in the conversation and lets them follow the best path to consumer happiness, which helps us deliver those superior experiences to every individual.” 

By focusing on the individual, Halsted can ensure they are treating everyone they speak with as a person who has something to contribute, not an account.  By partnering with Prodigal, Halsted aimed to learn as much as they could about the consumer experience. It’s a great goal to have; it means we’ll always evolve to match their needs. And that’s exactly what improving customer experience requires.

About Halsted

Halsted Financial Services is the expert in omnichannel collections. Headquartered just north of Chicago, with near-shore and off-shore captive sites, Halsted uses proprietary, state-of-the-art technology to run a single platform, omnichannel solution. At Halsted, voice, email, SMS, digital marketing, web chat, and a dynamic payment portal are wholly integrated into one system that updates events in real-time, giving consumers the flexibility to communicate with us when convenient for them and in the manner with which they are most comfortable. This leads to great customer experiences. Halsted has developed a reputation as a trusted business partner that achieves results while protecting the valued reputation of its clients. 

To learn more, visit halstedfinancial.com

About Prodigal

Prodigal is a cloud-based Consumer Finance Intelligence solution that analyzes agent and customer conversations to enhance profits, experience, and compliance. Agencies, healthcare providers, and lenders depend on Prodigal to unlock insights that drive win-win financial outcomes. With decades of industry and data science expertise, Prodigal is ready to work with clients to optimize operations and quality assurance. Nearly one in five U.S. borrowers have already engaged with Prodigal during more than 200 million interactions.

Headquartered in Mountain View, California, Prodigal’s global team is on a mission to build the intelligence layer that powers Consumer Finance. With the backing of domain experts, technology leaders, and top investors, including Accel, Menlo Ventures, and Y-Combinator, Prodigal is poised to become the next iconic vertical SaaS company. To learn more, visit www.ProdigalTech.com or follow @ProdigalTech.

St. Paul, Minn. — IC System hosted its annual Charity Golf Tournament at Tanners Brook Golf Course in Forest Lake, Minnesota, on Friday, July 15. Now in its 24th year, the event brought IC System employees, vendors, and business associates together for a day of course games and friendly competition for a good cause. This year, the tournament broke its record for charitable donations.

Every year, IC System tries to out-perform the previous year’s contributions. The 2022 tournament established a new precedent, raising over $30,300 for several charities. Over the last 24 years that IC System has held this event, its golfers have helped raise about $180,000 for worthy causes.

The 2022 charities consisted of four of IC System’s longtime causes. A Soldier’s Child Foundation helps the children of fallen military personnel. Feed My Starving Children packages and distributes food to children in need in over 70 countries worldwide. The American Cancer Society is a nationwide organization committed to ending cancer. Last but not least, The Ronald McDonald House supports various programs that directly improve the health and well-being of children.

IC System donates to these charities all year round, but the annual Golf Tournament is the biggest single contributing event.

Besides golf, players had other ways to raise funds for these worthy causes. Every few holes featured a pay-to-play course game that helped raise funds for each charity. Players could Chip for Charity, participate in the Bag Toss Challenge, or compete in the Minute to Win It cup contest.

“We had an amazing tournament,” said Rocky Bzdok, IC System’s Compliance Assurance Specialist and one of the tournament’s organizers. “We were very fortunate to have good weather, generous players and sponsors, and a great time golfing. IC System is proud to support this event, which truly impacts the organizations that support our communities. Of course, we could not do this without all the support we get from our vendors and employees.”

About IC System

IC System is one of the largest receivables management companies in the United States. In business since 1938, IC System is a family-owned, privately held accounts receivable management firm in its third generation of family ownership. IC System provides customized debt recovery solutions for healthcare, dental, small business, government, utilities, financial services, and telecommunications industries on a nationwide scale. Follow IC System on Twitter at @icsystem or on Linkedin.

A group of 12 Republican Senators have sent a letter to CFPB Director Rohit Chopra in which they urge him “to reverse course and stop using inappropriate tactics to harm financial institutions’ reputations and customer relationships in order to advance your liberal policy preferences.”

In their letter, the Senators assert that “rather than operating as a tough, but fair and sensible regulator, the CFPB is again pursing a radical and highly-politicized agenda unbounded by statutory limits.”  As examples of “uncontrolled and unwarranted” CFPB actions, the Senators point to the following:

• The CFPB’s use of “name-and-shame tactics to pressure companies into eliminating [overdraft fees].”  The lawmakers’ point to the chart published by the CFPB in February 2022 that listed the top 20 banks by revenue from overdraft fees and statements made by Director Chopra in his July 2022 media interviews indicating that he was “gratified to see where the market has been shifting” while warning that the CFPB would be “increasing our supervisory scrutiny of the institutions that are most dependent on [overdraft fees] as part of their deposit account revenue.”  The Senators state that “[i]t is hard to view [this] statement as anything other than a threat that banks who do not bow to the CFPB’s pressure campaign could expect the agency to target them for increased supervision.”

• The CFPB’s change in its risk-based supervision rule to allow the CFPB to publicly disclose a decision to subject a nonbank to risk-based supervision.  The Senators observe that the rule change “did not give a nonbank the same discretion to defend itself and instead requires a nonbank to keep confidential information relating to the CFPB’s decision, including facts that could call into question the Director’s decision or raise procedural concerns with it.”  The Senators state that since the CFPB has never used this authority, the rule change “appears to serve as a threat to nonbanks…whose practices are legal but not in line with your liberal policy views.”

• The CFPB’s change in its rule on adjudication proceedings to allow the Director, at any time, to direct that any matter be submitted to him or her for review.  The Senators assert that this change allows Director Chopra to “authorize CFPB staff to bring an enforcement case based on a novel legal theory and then you can personally rule that it is a valid theory.”

• A mass email sent by the CFPB to the customers of a bank that is the subject of a CFPB enforcement action about accounts alleged to be opened without customers’ consent.  The Senators assert that the mass email “was not a legitimate investigative or litigation tool, but rather a means to damage the bank’s customer relationships.”

We recently urged Director Chopra to discontinue the CFPB’s current practice of using a potpourri of methods that lack transparency and predictability to interpret federal consumer financial laws.  In our open letter, we called on Director Chopra to instead restart use of the official staff commentaries that are subject to input from stakeholders and provide certainty that they will be binding.

We are surprised that in their letter, the Senators did not criticize the CFPB’s updates to its Supervision and Examination Manual that instruct examiners to consider discrimination in connection with non-credit products and services as an unfair act or practice.  For the reasons we have discussed, we believe the CFPB’s UDAAP interpretation is legally flawed.  Moreover, given the complexity of the questions the CFPB’s expansion of UDAAP raises, we believe this type of a drastic change should be done through a rulemaking and not through an amendment to an examination manual.

POTOMAC, Md. — Women in Consumer Finance (WCF) recently renewed its partnership with industry innovator Spring Oaks Capital to support The Magic of Connection for attendees at its annual unique in-person professional development experience. This year’s event will be held December 5-7, 2022, in Palm Springs, California.

WCF provides inspiration, a guiding hand, and a support system women can leverage to recharge their careers and deliver value to their employers. The event is not about compliance, best practices, or even finance. It’s about women, our common professional challenges, and how to create and tell our own career story – no matter where we are on our professional journey. We take a unique approach to building confidence, connection, and careers. There is nothing else like it.

At the center of that unique approach is the way we ensure all attendees leave the annual event with deep connections forged through a shared experience. We call this “The Magic is in the Connection.”

“This is an investment in your current and future leaders. If you’re not investing in them, someone else will. These are the people who are making decisions that impact your business by millions of dollars. So a few thousand dollars to support their own personal and career development isn’t much to ask,” said Marcelo Aita, Executive Chairman, Spring Oaks Capital. “Women in Consumer Finance is an essential part of our talent development program.”

“As an introvert myself, I can totally identify with how intimidating it can be to meet new people at a conference. Yet new relationships are absolutely an essential part of professional growth. So we focus intentionally on creating a shared experience in a manageable way. Attendees are assigned to small teams that meet even before the event starts. This makes the conference feel intimate and friendly,” explained Stephanie Eidelman, Women in Consumer Finance CEO and Co-Chair.

This year, we’re incorporating team leaders for the small groups. These are volunteers who have previously attended the conference and who will make sure that nobody gets left behind (literally and figuratively). If you’re an introvert or new to the event, these are your people. We don’t want anyone feeling uncomfortable or out of place, as every woman has a place at our table.

We’d like to thank our Magic is in the Connection Sponsor, Spring Oaks Capital, for recognizing what’s truly unique about Women in Consumer Finance and supporting the event as one of our largest sponsors.

About Women in Consumer Finance

Women in Consumer Finance is an event and community for women at all levels in the context of a common industry. If you work in any role at a lender, creditor, servicer, law firm, technology or service provider, or regulator, this event is for you. We provide inspiration, a guiding hand, and a support system women can leverage to recharge their careers and deliver value to their employers. WCF is not about compliance, best practices, or even finance. It’s about women, our common professional challenges, and how to tell our own career story – no matter where we are on our professional journey. We take a unique approach to building confidence, connection, and careers. There is nothing else like it. WCF 2022 takes place in person in Palm Springs, California on December 5-7. www.womeninconsumerfinance.com

About Spring Oaks Capital

Spring Oaks Capital is a national financial technology company focused on the acquisition of credit portfolios. The company subscribes to an employee and consumer-centric operating philosophy that creates high-value jobs, a significant performance lift, and the highest standards of compliance. Spring Oaks’ business strategy is rooted in innovative data-driven technology to maximize collection results and a contact platform that offers multi-channel options to meet each consumer’s communication preference. Spring Oaks has the management vision and experience to nurture a culture and DNA that is unique in the space. The executive team maintains deep experience end-to-end across the consumer finance lifecycle with some of the largest global banks and innovative FinTech platforms. To learn more about Spring Oaks and our revolutionary FinTech platform, please visit www.springoakscapital.com.

BURLINGTON, Mass. – Finvi, a leading provider of enterprise workflow automation software built to accelerate revenue recovery and simplify the payments process, recently launched a new integration between its payments platform and Katabat workflow software. With the addition of the embedded Finvi Payments solution, Katabat is now an all-in-one workflow and payments platform designed to increase collections rates and streamline operations through a combination of powerful digital engagement and payment processing tools.

This new integration offers Katabat users built-in compliance rules and modern, digital communication capabilities, such as text messages and emails, combined with convenient, familiar payment options (e.g., debit, credit, and ACH) to help meet the demands of today’s mobile, fast-paced world.

As the popularity of digital payments has increased over the years—with transaction volume expected to reach $1,765B in 2022 and an estimated $3,528B by 2027, according to Statist—not having a self-service online payment option can cause friction and impede collection efforts.

The new payments option not only allows agents to take payments over the phone via credit, debit or ACH directly within the Katabat portal, but also provides these same options for clients through a self-service portal, giving them the 24/7 access they have come to expect. 

“Today’s consumer demands convenience and flexibility—as a true partner to our clients, we want to help them offer that convenience in the easiest possible way,” said Tim O’Brien, Finvi’s CEO. “This new all-in-one solution does that by giving our clients everything they need in one implementation—omnichannel communications and modern payment options. The days of promissory notes and paper checks are gone.”

With text messaging quickly gaining popularity as one of today’s primary forms of communication, the addition of secure payment options to Katabat’s already robust digital and omnichannel communication platform was the next logical step in the product’s innovation. 

“Having the ability to reach consumers via their channel of choice, including text or email, is key for our clients,” explained O’Brien. “Our number one priority is to provide the advanced technology our clients need to drive revenue recovery success. With that in mind, we couldn’t be more excited to offer this functionality to our Katabat clients.”

Interested in learning more about this integration? Sign up for a live webinar on Monday, September 26, 2022.

About Finvi 

Formerly Ontario Systems, Finvi is a premier provider of enterprise technologies that streamline and accelerate revenue recovery for clients across healthcare, government, accounts receivable management, and financial institutions. Through process automation and modern, compliance-minded communication and payment tools, Finvi allows its client partners to generate more revenue at reduced cost and fulfill their stated business outcomes by effectively engaging those who pay. 

With offices in the states of Massachusetts, Indiana, New Mexico, Delaware, and Washington as well as employees across the country, Finvi continues to build upon 40 years of success using a distinctly human-centric approach to innovation and service. A recognized brand in the revenue cycle management (RCM) market, Finvi helps 600+ hospital networks—including 5 of the 15 largest systems in the U.S.—optimize cash collections and provide a single, satisfying patient financial experience. Finvi also serves 8 of the 10 largest ARM agencies in the United States as well as a number of financial institutions across the globe. Additionally, Finvi’s workflow platforms power governmental agencies and court systems across the country at the federal, state, and municipal levels. 

Rochester, N.Y. — Continental Service Group, Inc., d/b/a ConServe, a leader in the collections industry, proudly announces that it has added Alicia McKeighan to their Compliance department in the role of Associate Vice President, Compliance.  In this new role at ConServe, McKeighan will oversee the company’s compliance and ethics team, by working closely with ConServe leadership, employees, Clients and their Consumers to ensure best-in-class compliance practices.

With over 37 years of success in the industry, ConServe has defined itself as an innovator and role-model in the field while effectively redefining collections by understanding that compliance matters.   

“We are thrilled to add Alicia to the ConServe team,” said Pam Murphy, ConServe Vice President of Compliance and Privacy Officer.  “Amidst the dynamic changes in the collection industry over the years, our focus on ethics and compliance ensures the highest standards of compliance, ethics, risk management and increased corporate governance.  Expanding our team and bringing on Alicia anchors that commitment.”

McKeighan has been in the accounts receivable management industry for 13 years and was formerly the Chief Compliance Officer at Afni, Inc.  During her 13 years in the industry, she has acquired experience in litigation management, regulatory interactions, service provider oversight, complaint handling, credit reporting, audit and monitoring, policies and procedures, and training.  She has served on ACA International, Inc.’s (ACA) Ethics Committee and Federal Affairs Committee in past years. Additionally, she was a member and active participant in InsideARM’s Consumer Relations Consortium.  She also held the Credit and Collection Compliance Officer (CCCO) and the Scholar and Fellow designations with ACA International.  Alicia is based in central Illinois and loves spending time with her family.  McKeighan states, “ConServe’s commitment to doing the right thing at the right time, the right way, aligns well with my personal values.  I am eager to join ConServe and its best-in-class compliance team to reinforce and strengthen ConServe’s efforts and commitment to Fostering Financial Freedom® for their Clients and their Consumers.” 

About ConServe

ConServe is a top-performing accounts receivable management service provider specializing in customized recovery solutions for their Clients.  Anchored in ethics and compliance, and steadfast in their pursuit of excellence, they are a consumer-centric organization that operates as an extension of their Clients’ valued brands.  For over 37 years, they have partnered with their Clients to provide unmatched customer service while simultaneously helping them achieve their accounts receivable management goals.  Visit us online at: www.conserve-arm.com

On August 30, the California Department of Financial Protection and Innovation (CA DFPI) published a notice of rulemaking action, proposing amendments to the Student Loan Servicing Act.

According to the CA DFPI, when the Student Loan Servicing Act first became effective in 2017, student loans contained traditional student loans, defined in the proposed rules as federal student loans, and private student loans offered by traditional lenders, such as banks and credit unions. In the last five years, education financing products, such as income share agreements and installment contracts, have emerged. The proposed rules clarify that such products are student loans, and servicers of such products are covered by the Student Loan Servicing Act and must be licensed.

The proposed amendments’ stated objectives include:

• Clarifying that all education financing products are student loans within the definition of student loan in the Student Loan Servicing Act and the Student Loans: Borrower Rights law;

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• Clarifying that servicers of all education financing products must be licensed as student loan servicers under the Student Loan Servicing Act;

• Clarifying that servicers of all education financing products are subject to and must comply with all laws applicable to student loan servicers;

• Defining terms used in the rules relating to education financing products;

• Specifying that servicers of all education financing products must submit an annual report to the department regarding the volume and dollar amount of all education financing products serviced during the previous year on the form specified by the CA DFPI; and

• Revising certain existing regulations to remove requirements deemed unnecessary, based on the CA DFPI’s experience administering the Student Loan Servicing Act, to reduce regulatory burden.

The notice triggers a 60-day comment period (ending October 28) for interested parties to submit comments.

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DENVER, Colo. — Harvest Strategy Group is pleased to announce the addition of Pete Klipa as Chief Operating Officer. Mr. Klipa brings 20 years’ executive experience in the accounts receivable space with a strong consumer-focused perspective. His experience includes eight years with Discover Financial Services as senior manager of recovery. Mr. Klipa will be a valuable asset to the team, as well as to Harvest’s clients and vendor partners, as he brings his cross-functional leadership background to further the quality, efficiency, expertise, and performance on which Harvest has built its reputation. 

“Pete has a proven ability to successfully manage large scale recovery operations, analyze processes and performance, and implement sophisticated operational standards and growth metrics. Pete’s talent and expertise will also support our growth and diversification objectives,” said Brad McCurnin, President and CEO at Harvest.

“I’m
excited about the opportunity to apply my strengths and experience for the
benefit of a great company, our partners, and the consumers we serve. When the
role presented itself and I met the team, I knew this was where I belonged at
this point in my career. With Harvest’s analytics-driven operations and strong
vendor network, I know we’ll do great things together,” said Mr. Klipa.

Mr.
Klipa spent 2018-2022 as SVP of Creditor Relations for the National
Foundation for Credit Counseling in Washington, DC.
There he directed creditor activities by developing, implementing, and
maintaining proactive and positive relationships with and between financial
institutions, member agencies, and the organization. He served as an advocate
for consumers, engaged with the top twenty credit card operations and
marketplace lenders, optimized operations, and implemented emerging
technologies. Mr. Klipa also met with the CFPB and OCC regarding strategy and
regulatory opportunities. 

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From
2003-2018, Mr. Klipa established his robust loss mitigation and recovery leadership
capacity in several long-term management and executive roles across the
accounts receivable management industry including American Credit Acceptance,
Discover Financial Services and NiSource Corporate Services. He managed
recoveries for major companies in the utility, credit card, and automotive
finance fields, building out operations, managing vendor relationships,
providing performance oversight, producing valuable metrics tracking and
analysis systems, and measurably boosting performance.

After
earning his B.S. in Mathematics and Business Administration from Otterbein
College in Westerville, OH, Mr. Klipa originally began his career with the
United States Air Force as a Cost Analysis Officer in the Electronic Systems
Center at the Hanscom Air Force Base in Massachusetts. During this time, he
earned his M.S. in Systems Management from Western New England College. He then
spent ten years in finance and analyst roles for a utility provider in Ohio,
accumulating increasing knowledge and responsibilities until becoming the
company’s Director of Revenue Recovery. 

About Harvest
Strategy Group

Harvest
Strategy Group provides single-point-of-contact,
nationwide recovery management services for banks, finance companies, debt
buyers, and credit unions. The company fosters an entrepreneurial environment
and encourages its staff to challenge boundaries, think outside the box, and feel
a sense of ownership and accountability for results. Harvest’s mission is to
lead the accounts receivable management industry through strength in
partnerships, exceptional service, and the delivery of superior results. To
join the team, apply
to Harvest Strategy Group online.