Recently we heard a comment from a client about hearing from their OCC examiner. They said “Payment programs offered on the web are not what we want to see”. When we first heard this story we were concerned – we talked to an examiner who recently left the OCC and got a different story. So I guess we’re left wondering, have any of you personally heard this from your OCC examiner? Or is it a case of “I heard from someone, who heard from someone, who heard from someone else”?
To clear things up, the official source on uniform policy, specifically the part about making program offers, reads that “documentation normally shows that the institution’s personnel communicated with the borrower, the borrower agreed to pay the loan in full, and the borrower has the ability to repay the loan”. Basically, they don’t want to see a “one size fits all” offer. Individualizing our approach seems to be the key thing they are after.
Platforms like FlexCollect offer a simple solution to proving this individualized approach. There’s the ability to prove the interaction with the borrower. You can capture data at the individual customer level and verify the evidence you need for willingness and ability because it’s systemically controlled by your computer. You can prove a fair and consistent program offering which is individualized to a unique borrower experience. All at an account – level audit trail.
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