American Recovery Service is built upon a foundation of commitment to progressive, flexible, and creative business solutions. Our proactive approach to all of our client needs requires forward thinking and early identification of industry trends. It is through this progressive mindset that we develop a distinct understanding of the realities of our industry.
Day after day restrictions and regulations are imposed on the business of repossession in ways most in the industry may not have predicted. Our client partners, sharing our understanding of the cost and liability of maintaining compliance, look to ARS as a trusted source to smooth their path and ensure that their needs for vehicle recovery are met without resistance and without undue exposure.
How did we respond to this need?
We recognized early on that we had a responsibility to react proactively and safeguard our clients’ needs, our corporate health, and the health of the repossession industry as a whole. Our response was to invest internal resources with a focus on engaging innovative business practices that provide fully compliant recovery services while meeting our clients’ ultimate needs; safe retrieval of their collateral.
During a time when the term “compliance” was virtually an unknown concept, ARS took the lead in pioneering two important initiatives:
Implementation of a comprehensive site inspection program.
- Inclusive of thorough compliance inspections for the entire ARS collateral recovery agent network at no cost to our agents.
Development of an in-house Compliance division.
- Lead by our Chief Compliance Officer, this team is dedicated to monitoring the industry regulatory environment and serving as a resource to our professional partners.
Creating a division to oversee our audit program was just the starting point. Fostering a culture within our organization wherein each team member takes a hands-on approach to compliance was also a necessity. As a whole we continuously seek to not only prevent non-compliance and detect the potential for non-compliance, but also to formulate plans of action specifically tailored to mitigate risk.
Developing a system of written policies and procedures was the next step toward fulfilling our commitments. Dave Baker, Chief Compliance Officer added, “Policies and procedures on their own are merely tools unless they are placed in the hands of competent users. That’s where our teams really shine. Each and every day, throughout each step from intake to finalization of an assignment, our teams work tirelessly to ensure that our compliance program is not only effectively executed, but categorically compliant. Actively working to limit, or even better, to eradicate the potential for statutory, regulatory, or SLA violations is at the heart of a successful compliance program.”
What are some key factors in maintaining compliance?
As we see it, all of the below are vital pieces of a comprehensive and effective compliance curriculum:
- Keeping abreast of changes in federal and local regulation
- Adherence to client specific MSA’s and SLA’s
- Consistent, timely, and appropriate training of all staff and vendor partners
Maintaining and frequently updating internal policies, procedures, and training materials to reflect all current requirements.
- Ensuring proper licensing and insurance is in place at all appropriate levels
- Timely audits both internally and externally, across all systems
Setting clear expectations, providing accurate instruction, ensuring prompt remedy to address any gaps
- Conducting thorough due diligence to verify we understand industry regulations and standards
Sara Schelk, ARS’ VP of Special Operations stated, “Staff acceptance in the early stages paved the way and led us to where we are today. Our Compliance team was at the forefront, piloting the company and successfully steering it in the correct direction. The process developed naturally and allowed us to set high expectations that our staff readily met. We have been provided the tools to not only lead our teams, but hold them accountable.”
Industry Accountability…Who is responsible?
The short and obvious answer to that question is: We are all responsible.
Accountability starts, but does not end with the lender. Accountability also lies with the servicer and all of its employees and vendor partners. Creating layers of accountability at each level, creating defined processes and protocols, and working diligently to ensure all parties remain in compliance is vital.
Meeting lender requirements, as they interpret CFPB regulations individually, can be complex and challenging. Fortunately, ARS had the foresight to develop a Compliance division with the intent to build consumer protection compliance into all aspects of our operations. As a result, we have the tools, capability, and agility to meet these challenges. Our ability to stay ahead of the curve as it pertains to compliance gives us a competitive edge in the repossession industry.
As stated by Cortney Osborne, ARS’ Senior VP of Operations, “Since its development in 2008, the ARS Compliance management team has taken a proactive and revolutionary approach to complaint tracking, policy implementation, and agent education by managing this core piece of our business in-house. Marrying the initiatives to protect our lenders’ brand identity while exceeding performance expectations has been our top priority and we have accomplished this goal through employee education seminars, quarterly policy review attestation meetings, and company-wide CARS certification.”
Today our Compliance division is at the top of the game and operates with a level of expertise that our clients find not only impressive, but more importantly, in direct line with their goals, objectives, and compulsory needs. Our clients know they can rest easy in the knowledge that ARS’ team of professionals is dedicated to ensuring every single account is handled in a fully professional, capable, and compliant manner.