Where Are You? Strategies for Locating Borrowers
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1 Where Are You? Strategies for Locating Borrowers
2 Borrowers that do not have current contact information with the lender/servicer These borrowers cannot always be easily found 50-60% of borrowers who default are skips
3 Agenda Review the terms of the Master Promissory Note Discuss the laws and regulations Learn what s required of servicers to locate borrowers Discuss tools to locate borrowers Share what you can do to help
4 Terms of the Master Promissory Note
5 Master Promissory Note Legal document A promise to repay loans Outlines rights and responsibilities of borrower and lender Explains terms and conditions of loan
6 What the Borrower Agrees to The borrower s signature on the Master Promissory Note is an agreement to Provide any changes to their name, address, or telephone number
7 What the Borrower Agrees to The borrower s signature on the Master Promissory Note is an agreement that allows Their loan servicer to provide information to their immediate family members and references References to be contacted
8 Broken Agreement Borrowers break the terms of their MPN when they don t Repay Provide updates of their name, address, or telephone number Borrowers who break the terms of their MPN will often disconnect
9 Broken Agreement Borrowers who disconnect: May not know who their servicer is Ignore telephone calls and correspondence from their servicer Do not notify their servicer of changes to their address and telephone number
10 Why Borrowers Disconnect
11 Laws and Regulations
12 Following the Rules Laws and regulations set the framework for what can and cannot be done Federal laws State laws Consumer Financial Protection Bureau Federal regulations Common Manual
13 Federal Laws Higher Education Act of 1965 Dodd-Frank Act Unfair, Deceptive Acts and Practices (UDAAP) Fair Credit Reporting Act (FCRA) Gramm-Leach Bliley Act Servicemember s Civil Relief Act (SCRA)
14 What Does that Mean for Federal Servicers Must comply with HEA Must not discriminate in any aspect of loan servicing on basis prohibited by applicable federal law Ensure that service members receive the benefits they are entitled to receive
15 What Does that Mean for Federal Servicers Must not employ unfair, deceptive, or abusive acts or practices in the servicing of any loan When applicable, do not disclose personal identifiable information to a third party
16 State Laws Many states have debt collection laws that go beyond some federal requirements
17 Great Lakes Follows Various State Laws Examples of practices we do not do Threaten action that we don t intend to take Make misrepresentations Use profane language Call prior to 8:00 am and after 9:00 pm Include information on an envelope about a debt Call multiple times per day
18 Consumer Financial Protection Bureau Created out of the Dodd-Frank Wall Street Reform and Consumer Protection Act Assigned the role as the primary regulator with respect to rulemaking and enforcement authority Sets specific student loan procedures for federal and private loans
19 Consumer Financial Protection Bureau CFPB s examination reviews Board and management oversight Compliance program Consumer compliant response Compliance audit
20 Communicating with Third Parties When talking to third parties We cannot communicate about the borrower s debt with other people, unless we receive permission by the borrower In some states, we cannot say where we are calling from unless asked
21 Disclosures We Make Provide the Mini Miranda when talking to borrowers Fair Credit Reporting Act State that the call may be recorded or monitored
22 What s Required of Servicers to Locate Borrowers
23 Due Diligence There are no specific due diligence regulations to the servicing of Direct loans Great Lakes follows FFELP regulations for completing due diligence for FFELP and Direct loans
24 Regulation Due Diligence Address skip Use effective commercial skip-tracing techniques, letters or other contact efforts Phone skip Directory assistance inquiry Letter or other contact efforts
25 Common Manual Due Diligence Common Manual outlines due diligence requirements Same requirements are used for Direct and FFELP loans
26 Common Manual Due Diligence Make two attempts to each reference on different days and at different times Make two attempts to each borrower s telephone number (if in address skip) on different days and different times Send request to external vendors
27 Common Manual Due Diligence Review documents on file for updated information and additional references Send requests to schools and lenders for updated contact information
28 Beyond Due Diligence What Great Lakes does beyond requirements Sends s Makes additional phone call attempts Performs manual on-line searches Sends accounts to a third party with whom we contract
29 Great Lakes Skip Tracing Approach
30 Goals Improve borrower contact information Investigate new products to locate borrowers Enhance our system to be more effective and efficient
31 Skip Tracing Approach Follow regulations and guidance to ensure due diligence is completed Send daily batch files to external vendors LexisNexis CBC Innovis Credit Reporting Agencies
32 Skip Tracing Approach Any new address received is put on the system and the borrower is removed from address skip Phone numbers received are sent to another vendor for validation If the data is highly validated, the borrower is removed from skip
33 Tools to Locate Borrowers
34 Skip Tracing Tools Many options that can be used to locate borrowers Fee-based and free products/tools
35 Skip Tracing Tools Fee-based Vendors Batch files Evaluate and compare to determine the rate of correct information Online searches Can cost from $.25 to $2.00 per search
36 Skip Tracing Tools Free Most free tools are manual searches Can take a significant amount of time
37 Skip Tracing Tools Free Voter registration records Property tax assessor Military locator Professional licensing records Alumni sites Public record finder Federal and state prison locators
38 Social Media Social media is also a manual process but can be used to gather some information to help locate a borrower Date of birth City Place of employment Married or changed name
39 Social Media Facebook MySpace Twitter Foursquare Flickr LinkedIn Instagram
40 Social Media As a servicer, we re not allowed to use social media to Converse with our borrower or their friends Request to be added as a friend Pretend to be someone else
41 What You Can to do Help
42 Annual Updates Collect contact information and references annually from your enrolled students
43 Locating Borrowers 1. Review reports for unknown contact information NSLDS Delinquency Borrower Report (DELQ01) Servicers reports 2. Utilize internal and external resources to locate delinquent borrowers 3. Update contact information to federal servicers
44 Providing Updates to Servicer Only provide demographic data from a reliable source Only provide new data Within the last 45 days Provide the source and effective date
45 Providing Updates to Servicer Use Great Lakes Outdated Contact Response to provide updates
46 Communicating with Borrowers and References When contacting borrowers and/or references Use a pleasant tone Use voice volume control Listen Stay calm
47 Communicating with Borrowers and References When contacting borrowers and/or references Don t take comments personally Show empathy Thank them regardless of outcome
48 Conclusion
49 Locating Your Borrowers Wrap Up Be aware of laws and regulations Consult with your legal counsel before conducting skip tracing Use external resources wisely Free sites are not free if it takes a large amount of man power Evaluate fee-based resources to determine rate of investment
50 Teamwork Approach We can work together by sharing missing borrower data Use loan servicer reports/tools to gather and share demographic data Stress to borrowers that their loan servicer is here to help remove barriers
51 Thanks for Attending Great Lakes Higher Education Corporation & Affiliates
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