In the first part of his series, Intellaegis president John Lewis offered three suggestions on creating a mock audit to prepare for a potential examination by the Consumer Financial Protection Bureau.

To wrap up the blog endeavor for SWBC, a diversified financial services company that has interests in the automotive world along with insurance, mortgage banking and wealth management, Lewis went back to his kindergarten theme to generate six basic principles regarding current compliance challenges when it comes to repossessions and recoveries.

“Let’s go back to kindergarten for a minute when life was simple and the rules were based on common sense,” Lewis wrote in this blog post before going into his six points, which are:

1. Share everything

Lewis insisted transparency through tracking in cutting-edge software is now a “must-have” for gathering, sharing and tracking all data that relates to customers and what happens on their account in collections — be it internally or externally within a vendor network.

2. Play fair

Lewis recommended that finance companies identify and eliminate “bad actors.”

He said, “You’re not playing fair if you’re employing or hiring people who do not treat your customers with the respect they deserve.”

3. Clean up your own mess

Lewis suggested that finance companies identify issues inside the organization or within a vendor network before they become problems.

“Create solutions that address issues and problems that arise, so you don’t keep dealing with the same mess over and over again,” he said.

4. Don’t take things that aren’t yours

Lewis emphasized that wrongful repossessions should be avoided at all costs.

“By using repossession assignment software that ties you and the repossession vendor at the hip, wrongful repossessions will not occur,” he said.

5. Say you’re sorry when you hurt somebody

Lewis recollected a famous part of the Watergate investigation that noted, “The cover-up is worse than the crime.”

He added, “The CFPB sees (and rewards you) when you catch and resolve issues internally without a regulator having to tell you what to do.”

6. Wash your hands before you eat

Lewis closed his series by noting the segment he said “may be the most relevant of all, and it should be the largest concern of every small- to mid-sized lender who does not have the resources to have a fully staffed compliance and security department.”

He referenced an idea from SWBC asset recovery program manager Karen Townsend, who pointed out that “an internal lack of expertise can truly impact your bottom line.”

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. The Re3 Conference is the portion of Used Car Week dedicated to helping organizations gain the best insights to aid their efforts in repossessions, recoveries and remarketing.