In keeping with our goal of providing professional certification and compliance training documents to the collateral recovery and lending industries, RISC has been working with the National Alliance of Buy Here, Pay Here Dealers (NABD) to provide these services to Buy Here, Pay Here (BHPH) automobile dealers.
BHPH automobile dealers are required to meet mandates of the Consumer Financial Protection Bureau (CFPB) just as lending institutions do. If BHPH dealers also perform their own in-house repossessions they must face recovery compliance mandates as well.
In working with NABD it has been our intention to address the CFPB compliance mandates and assist BHPH dealers in the areas of self-help repossession activity and protecting Non-Public Personal Information (NPPI). This information enables BHPH dealers to make more informed choices on whether they will handle their own repossessions in-house or assign those repossessions to certified, insured independent collateral recovery specialists.
Courts across the country are holding creditors liable for the acts of the collateral recovery specialists they utilize, so the decision of whether to train and use their in-house employees or independents is very important. Further, BHPH operators must train their employees to protect their consumers’ non-public personal information from third party disclosure. For all these reasons it is recommended that only certified, insured, independent collateral recovery specialists be used in recovery. As this is not always feasible, RISC offers two important training guides to mitigate risk: the BHPH National Certification Program and the BHPH Compliance and Operations Manual. These programs are designed to train and certify BHPH employees who service in-house repossessions of their employer and assist BHPH operators in compliance.
RISC plans to participate in the NABD National BHPH Conference in Las Vegas May 21-23. Operators are encouraged to discuss their particular needs with RISC during that conference or call us at (866) 996- RISC (7472) for further information.
