Intellaegis president John Lewis recently compiled a two-part blog series for SWBC, a diversified financial services company that has interests in the automotive world along with insurance, mortgage banking and wealth management.

While Lewis geared his collections compliance recommendations toward credit unions, the initial three suggestions on creating a mock audit to prepare for a potential examination by the Consumer Financial Protection Bureau could benefit finance companies of all sizes.

Lewis structured his plan by taking a rudimentary approach, viewing the entire process as if it were kindergarten.

“Having participated in a couple examinations by the CFPB with our clients who are top 20 auto finance lenders, we’ve seen firsthand why it’s important to get back to your roots — kindergarten,” said Lewis, whose company offers the skip-tracing and collection solution masterQueue.

Lewis again will be leading discussions during the Re3 Conference at Used Car Week, which runs from Nov. 14 to 18 at the Red Rock Resort and Casino in Las Vegas. Like he’s done at Used Car Week, Lewis gave a step-by-step process in his material for SWBC.

1. Audit your policies and procedures

“First, take a good look at all your internal policies and procedures,” Lewis said. “Look for gaps between the various state and federal laws, as well as the interpretation of these laws as seen in specific enforcement already taken by regulators against lenders and their vendors.

“This type of data is available, but it’s a big job to gather, organize and use to your benefit,” he continued.

To handle those chores, Lewis suggested that institutions reach out to local universities and seek assistance from college students who are looking for experience in conjunction with their education in a field related to auto financing.

“They benefit from the pay and real-world experience and we benefit from having a dedicated team that is able to focus on specific areas we normally wouldn’t, given limited staff resources,” he said.

2. Audit your service providers

Lewis reminded finance companies that in April 2012 the CFPB released a statement holding all institutions responsible for the actions of their external vendors.

“They have gotten more serious about enforcing this rule to the tune of hundreds of millions of dollars in fines not covered by your service providers’ insurance policies,” he said.

As a result, Lewis suggested that finance companies review their providers, including loan servicing companies, collection agencies, debt buyers, repossession agencies, skip or forwarding companies and door-knock companies.

3. Step up to the plate

Lewis closed this opening blog post — which can be viewed in its entirety here — with a blunt message.

“Finally, build a culture within your organization to do everything in your power to meet and exceed all these requirements. Complaining won’t do any good, so tell your complainers to ‘zip it,’” Lewis said.