Compliance is an interesting phenomenon in the industry today! I call it a “phenomenon” because that word means “Wonder”, “Marvel”, or “Spectacle”, and that’s exactly how I see compliance.
Compliance is this sort of unknown quantity, and everyone involved with it interprets it in a different way. One lender’s compliance is another lender’s non-compliance. Some vendors treat it with great respect, and others treat it like a scene from an old TV police drama, with a “Move along folks! Nothing to see here!” attitude. The number of interpretations of compliance is as numerous as the companies claiming to have all of the compliance answers.
We can all agree that compliance, in part, means having the proper insurance, licensing, contracts, etc. It also might include background checks on every employee, and onsite professional lot inspections.
Oh no! Did I say “professional lot inspection”? I really meant to say that we will hire someone from Craigslist and send them by to take a look at your lot!
Sadly, many compliance companies are building what is just another costly expense to the repossession vendor and calling it a “need” within our industry. These companies are taxing the vendor community with high rates for services that may or may not help them meet their lender’s compliance requirements. In reality, all they are is another revenue model supported on the backs of a financially stretched vendor community. They offer no meaningful opportunities for a vendor to improve their operations, reduce cost, increase revenue and ultimately eliminate risk.
Have you ever watched one of those nature programs where they show the Gooney bird coming in for a landing? They come crashing to the ground and roll two or three times before stumbling to their feet. That’s a perfect word picture to describe how “compliance” has come crashing onto the vendor community! As a result, compliance companies are popping up from everywhere each proclaiming to have “The Solution” for everything compliance related.
The way these companies view the vendor community reminds me of another bird; The Dodo bird! You might have seen a painting or statue of one of these in a museum, but none of us have ever actually seen one. That is because they are extinct. The last known account of a Dodo bird was way back in the 19th century. They were a fairly large, flightless bird that lived on isolated islands in the Indian Ocean. This isolation made them fearless of humans, and since they were slow moving, and flightless, they were easy prey for sailors.
Those selling a “bill of goods” on compliance think the vendor community is a flock of Dodo birds that will fearlessly trust their company’s data and reputation are secure in their hands. They spend a lot of time convincing the lender community that vendors are not capable of representing themselves professionally, and that they, as a third party, are far more capable and worthy of trust than the vendor community. I for one believe that no one will represent you better than you!
Don’t get me wrong, there are companies in the compliance space that certainly offer a valuable, affordable service to both the Lender and Vendor. These companies have been providing valuable services to the industry for years and have been a part of the vendor community’s push for greater transparency and professionalism. I leave it to the reader to determine the difference between a valuable compliance partner and one who has simply created a revenue model on the backs of a vendor community that cannot afford one more fee!
My intention is not to “sound the alarm” or even to “sling mud”! My intention is to make a “call for action” to those who currently provide technologies to the vendor community. As repossession industry technology providers we have a responsibility to the vendor community to provide low cost, integrated technology solutions that will enhance a vendor’s operational performance, reduce the cost of implementing compliance solutions, and place the vendor in control.
Compliance should not and cannot be a revenue opportunity supported on the backs of the vendor community! So, if compliance is not a revenue model, how can it be delivered to the vendor community effectively, and at a low cost?
No one is going to argue that compliance is not important. In fact, it is probably the single most important issue facing both the lender and vendor communities today. Compliance requirements are here to stay, and if any lenders or vendors are not taking it seriously today, they will tomorrow!
This industry already has several technology providers that bring great value to both the lender and the vendor by providing integrated technology solutions that allow for almost instant data transmission from lender to vendor and vice versa. Many of these technology companies are competing for the same customer but have found it vitally important to work together and integrate in a manner that reduces the need for vendors and lenders to access multiple systems. The level of cooperation in the industry today has never been higher, and will continue to improve over the next several months.
Because of this, a vendor is able to utilize one repossession management platform while automatically receiving an assignment from another, while simultaneously dispatching the assignment to a field agent’s smart phone. This same assignment’s update data is captured and instantly pushed to the lender’s system of record.
Just two short years ago the process I just described would have been impossible. Today, with the level of cooperation brought by the major technology players in the industry, this is becoming the norm and not the exception. Vendors and lenders both are demanding this level of connectivity and control. Lenders want immediate access to assignment and service provider data, and vendors want an increased level of control in managing and monitoring their organizations. Why settle for less when it comes to compliance?
Today, assignment data can be seamlessly shared between assignment management systems, LPR Providers, skip data providers, and the lender’s system of record, just to name a few.
Are we 100% there? No, but we are much closer to 100% integration than at any other point in the past. Technology providers have made integration a priority and we will continue to push this initiative until we have reached the industry’s expectations.
So what does compliance technology look like when it’s not a revenue opportunity?
Compliance is an opportunity for the industry’s technologists to provide low cost, highly effective, integrated solutions to the vendor and lender communities. Solutions that give the lender community the service provider data access they need, while keeping the cost to the vendor community as low as possible. In fact, the cost of compliance technology should be a wash to the vendor by balancing a minimal expense with highly scalable, efficient technologies that will reduce the vendor’s cost of compliance and increase their productivity.
This can only be accomplished by providing integrated solutions that work with the lender’s and vendor’s current assignment management platforms. By integrating contract management, complaint tracking and recurring training across multiple assignment management platforms, the industry’s technology partners will provide a feature rich, scalable, and low cost solution that will exceed the lender’s needs and the vendor’s expectations for compliance monitoring.
This is not a “what if” scenario! I am not informing you of what “can be” if only the technology providers would work together! This is not a pipe dream!
The integration of assignment management and compliance tracking already exists in MBSi’s Compliance Made Easy suite of solutions and we are committed to working with our integrated partners to ensure cross-platform capability!
Compliance Made Easy (CME) brings the lender and vendor communities everything outlined above and more. This integrated solution brings low cost, highly effective, and scalable compliance solutions to the vendor community.
Using CME vendors can upload 100% of their lender required documentation into a single lender-accessible portal that leaves the vendor in charge of their own data. What’s more, vendors can manage consumer complaints across a variety of assignment management platforms and establish recurring training for every employee.
By leveraging several of the existing system-to-system integrations developed, CME has introduced a line of products that integrate directly with a lender’s system of record as well as the vendor’s assignment management platform. The immediate access to data and ease of use has proven to be the catalysts for lender adoption. On the vendor side, the low cost and system integration capability have driven their adoption of CME.
For just $49.95 per month, vendors have a full suite of CME compliance solutions; Vendor Comply, Training Comply, and Contract Comply. The cost will not rise with the number of branches, users, or amount of data entered. This is a flat monthly fee for the use of every product in the CME suite of products.
We are committed to providing the vendor community with the necessary solutions to meet lender’s compliance requirements and to work with our technology peers in providing cross-platform integrated compliance solutions at a very low cost.
A good compliance solution is one that integrates with the vendor’s system of record and does not require access to yet another web site. It also places the vendor in charge of their data instead of a third party who refuses to take responsibility for the safety and security of the data provided.
While CME does provide integrated compliance solutions that meet the vendor’s need to adhere to strict compliance measures, it does not provide vendor vetting services. CME has partnered with quality companies such as RISC to provide these specific services at the lender and/or vendor’s request. CME is committed to working with those who provide a valuable compliance product to the vendor community.
Whichever assignment management platform you have selected for your company, call your provider and demand they work with their technology peers in providing integrated, cost effective, scalable solutions that place you, the vendor, in control of your compliance future.
About Compliance Made Easy
Compliance Made Easy includes two industry-first products from MBSi called Vendor Comply and Training Comply. It also features Contract Comply and partnerships with companies such as RISC to provide optional Vendor Vetting. The program comes at a time when the repossession industry is facing unprecedented regulation, where non-compliance can result in substantial loss of revenue.
The Vendor Comply Complaint Management System™ automates consumer complaint tracking and management in conjunction with a vendor’s internal assignment management software. The Training Comply Compliance Testing System™ allows lenders and vendors to create compliance and training tests, and automate test administration. These two industry-first products were developed to answer two key elements of CFPB regulations: Consumer Complaint Management and Recurring Training.
The Contract Comply module answers the lender’s need for centralized document handling that interacts directly with both the lenders and vendor’s system of record, but most importantly, keeps the vendor in charge of their own data. Additionally, each participating vendor will have access to MBSi’s Compliance Liaison to help answer all questions regarding specific aspects of lender-required vendor compliance relating to the vetting process.
President and CEO
MBSi Capital Corp.