Although, the final rules have not yet been adopted the CFPB has given a clear road map into the future. http://files.consumerfinance.gov/f/201210_cfpb_debt-collection-examination-procedures.pdf . For the last year, the CFPB has made it clear that; Dealers, Banks, Credit Unions and Auto finance companies will fall under their regulating authority. The CFPB has also made it clear that excessive fees, undue hardships placed on the consumer and discrimination on any level will be met with large fines and CFPB authority supervision.
The larger question the CBPB and governmental agencies will be asking going forward is, justification?
- Will you be able to justify the travel cost?
- How about undue hardships placed on the customer to redeem or recover the collateral?
- Scrutiny of all fees charged to the customer?
Will your remarketing /loss mitigation process withstand a CFPB audit? Will you be able to justify waiting two months while waiting to building an inventory for a sales Rep? How about moving the collateral 300 miles to fulfill an auction contract, or passing on travel cost and charging false fees? Many within the banking, collections, remarketing and loss mitigation world have chosen ignorance and fear over possibilities.
Not at GSF! Many years ago GSF Remarketing chose to embrace Dodd-Frank and the CFPB as the new business model. By embracing a new remarketing paradigm, GSF Remarketing not only brings compliance but removes the burdens placed on consumers. Working with local vendors and auctions, we’ve removed the undue hardships placed on the consumer, gone are the excessive fees charged to the consumer and welcome CFPB audits of our accounting practices.
GSF the future of Remarketing
GSF Remarketing is the only Minority Owned Remarketing Firm in the US CERTIFIED: DBE, SBE, MBE CERT & TGB