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ConsumerFi Podcast: Loss Mitigation with Carissa Robb of

January 14, 2021

Episode 13


Joel is joined by Carissa Robb, President and COO of the loss mitigation platform, Constant.Ai, to discuss the importance of non-traditional credit attributes outside of FICO scores, how blanket policies can lead to poor forbearance decisions and a rundown of Carissa’s recent article in the Non Prime Times, “Why 2.55 Million Repos in 2021 is Not the Answer”.

ConsumerFi is presented by Nortridge Software: Loan Software That Accelerates Change

And special thanks to The National Automotive Finance Association: The only trade association exclusively serving the nonprime auto finance industry.


[00:00:20] Carissa. How are you doing

[00:00:21] Carissa Robb: [00:00:21] you? Doing well. Thanks for having me.

[00:00:24] Joel Kennedy: [00:00:24] Thanks for being here, folks. We have Chris Rob. She’s the, uh, CEO and COO, right? Both, both hats,

[00:00:31] Carissa Robb: [00:00:31] uh, president and chief operating officer for constant.

[00:00:34] Joel Kennedy: [00:00:34] Yes. And chief operating officer of constant. Um, thank you very much for, uh, constant is, is kind of new to us in the auto and the non-prime auto it at least with, with the national automotive finance association have to thank you guys for sponsoring during COVID right.

[00:00:51] I mean, You’re coming out and, and kind of opening new doors during a tough time. So I really have to thank you for that. Um, additionally, [00:01:00] um, you know, after my own heart Carissa is, is, uh, also creating content. So. Uh, there’s going to be an article coming out shortly and non-prime times, um, kind of talking on, on the same topic and these are the types of podcasts that I really enjoy doing because we have something substantial data-driven to talk about.

[00:01:19] But I think, you know, for a lot of us, what’s really interesting is you and your background. So can you kind of tell folks about who you are and your background and then how it kind of led you to constant and what you guys do there? Yeah,

[00:01:34] Carissa Robb: [00:01:34] absolutely. Um, so I, um, joined constant in 2018 and we started off as a FinTech lending company.

[00:01:42] Um, so we did, um, uh, unsecured or UCC secure, uh, home energy efficiency projects, roofing loans, um, built a proprietary, um, loan origination platform. So we were doing online instant credit decisions. And, um, prior to that, I’ll get into [00:02:00] how we pivoted into the loss mitigation area. But prior to that, I actually ran, I was the senior VP for TD bank and ran us loan servicing.

[00:02:07] Um, and that position had evolved, um, from running loss, mitigation and collection units, uh, through the financial crisis, through the grape. The great recession. So, um, I spent a lot of time, uh, with, uh, winners that were struggling, um, trying to restructure, uh, those loans, avoid foreclosure, uh, keep her head above water with, um, super dynamic regulatory policies that were, uh, kind of changing on the fly.

[00:02:34] Um, most banks didn’t have loss mitigation at that time. And so we were really. Standing things up that were new, um, trying to do the right thing by consumers. And then also just deal with this overwhelming volume of, um, of folks needing help and, and pretty manual processes. So, um, from there. I took on, uh, roles that were heavily focused on governance and control.

[00:02:57] So, um, running our federal [00:03:00] audits with the spending a lot of time with the CFPB, the OCC, um, and our state state AGS, uh, for any, any kind of audit activity around loan, servicing and collections. And so part of that career path was, um, super informative because you’re dealing with. S really high pressure regulatory situations.

[00:03:20] Um, but it allowed me to pretty much ground my entire focus, my entire kind of approach to the industry and consumer protection. Um, so it wasn’t just about mitigating losses. It was also carrying this really heavy burden of making sure, you know, each step that we took forward was, um, considering consumer impact.

[00:03:39] Considering consumer harm, uh, and really trying to do the right thing. So all of that combined, um, allowed us to pivot, uh, about a couple of years into our lending program with constant, we decided, you know, the, the bottom’s going to fall out of this really strong market in 2019. Um, we’re going to see some delinquency pressure.

[00:04:00] [00:04:00] Uh, certainly couldn’t have predicted COVID. Um, but we thought. Now it’s time to, to think about how we can carry this automation that we’ve built in the front end, um, and really pull that through to the backend. So when our customers, if our customers started to experience them some financial pressure and, um, you know, delinquency, uh, we had a platform and a tool that would be there to serve them.

[00:04:22] Um, as you know, most of that’s pretty antiquated. Uh, in the back office today. So that’s how we evolved, um, from a lending company, uh, into a full, um, platform that services, hardships, loss, mitigation, uh, consumers who are experiencing a bit of trouble and, and apply the same kind of automation and controls to, um, to the backend.

[00:04:42] Joel Kennedy: [00:04:42] That’s awesome. And I had a chance, I had the fortunate opportunity to see a demonstration of your product and, um, I really like it. And we’re, we’re probably going to get into a little bit of that, especially when we get to the end where you have. But you’ve developed a nice sort of framework, strategic [00:05:00] framework for lenders to do some planning, um, because there’s, there’s some interesting tea leaves and I, I really love how you, how you, how you put this down in the article.

[00:05:09] And that’s what we’re going to dive into now. And the point of the article is about, I would, I would say, you know, having. Your head on straight knowing that you’re going to have to plan for some future loss mitigation strategies. If, if it’s not something you normally do or something, maybe you don’t do that much or do well.

[00:05:26] You’re going to want to look at that, but there are some indicators that we normally rely upon in terms of bringing onboarding, you know, credit quality that. You know, may not really be, uh, as powerful and indicator as they used to be because of all this stuff going on and the disruption with the stimulus.

[00:05:44] So, you know, really what we’re talking about is, is what are we seeing right now? And what are the strategies that we think will be helpful moving forward? You know, you start out in the article talking about some industry reports, highlighting the need for. For lenders to [00:06:00] really adjust their credit policies, to protect, um, the capital with the new originations.

[00:06:05] What types of things, um, along those lines, do you think, uh, lenders, uh, are doing or should be doing or should not be doing.

[00:06:14] Carissa Robb: [00:06:14] Sure. Um, so the first thing is just acknowledging that we’re, we’re exposed as a, as an industry, right? So, um, a lot of the attention has been on focusing on how we increase, um, or, or increase the number of decisions that can be automated.

[00:06:29] Well, to do that, you need to rely on attributes that are accessible in real time. FICO has always been a leading indicator. Um, it’s, you know, intended to represent credit worthiness. Um, and we may be a little bit exposed for that as a, as a leading indicator in credit models. So the first thing is not, you know, even if you don’t make drastic changes in your credit policy, now’s probably not the time to do that.

[00:06:51] It is worth acknowledging that there is some exposure and volatility in relying on FICO and how you price that asset on the front end. So, [00:07:00] um, there was a comment in the article that will come out that was talking about, um, a 32 point D difference between may of 2019. FICO’s in may of 2025 goes. Um, that’s, that’s significant.

[00:07:14] And if you look at the months before that, April 19 to April, 2020, There was hardly any movement. So what that’s underscoring or kind of highlighting is that the combination of you’ve got the surplus money coming in, supplementing income, you’ve got a forbearance and extensions pro programs kind of providing relief on the backend debt.

[00:07:33] And so true credit worthiness is a little bit distorted. We really know if a borrowers that are applying for credit that could be influenced by either one of those. Yeah, we’re actually going to be able to handle new debt. So if you, if you’re acknowledging that, um, w what, what we’re certainly encouraging, and the reason we created constant plus is start to look at non-traditional credit attributes, um, start to [00:08:00] strengthen or supplement your credit policy with key risk indicators that are, um, not lagging, uh, at nearly as bad as, as FICA would be, um, in the Bureau sense of, you know, lagging data.

[00:08:10] And then. Influenced by those kind of external

[00:08:13] Joel Kennedy: [00:08:13] factors. Yeah. And the good news is non-prime, um, at least in the deep subprime, um, the FICO score itself. Um, it, it, it’s not, it. It’s not as valuable as a standalone measure. Um, so most scorecards are built off of breaking out the individual attributes that are on the Bureau.

[00:08:33] So we use DMS and some other providers to do that. Um, that, that was interesting. So that, that, that increase. We saw that in the 2029 non-prime auto financing survey, that’s put out by national automotive finance association. I have to put a plug. Um, and as people to, to take a peak at that. But so with, um, we talked a little bit about the FICO score, kind of depreciate depleting.

[00:09:00] [00:08:59] And this one’s interesting to me because if you just look at FICO let’s, let’s take like a, uh, near prime population where the FICO is a more stronger indicator. Um, In that, in that scenario, uh, you know, like we said, it, might’ve lost some of the power of predictability for planning forward and that kind of set the table for, um, for some of your next actions that you were kind of diving into.

[00:09:24] Um, so you know, now we’re going to start talk a little bit about loss mitigation, obviously. So, um, and you have a very, uh, strong background in loss mitigation and in mortgage as well. Um, What starting from there in terms of, um, loss, mitigation strategies in light of the FICO, uh, depletion, you know, what, what type of things are you, are you, are you kind of recommending or advocating at that point?

[00:09:51] You mentioned some alternative data. Um, but what else.

[00:09:55] Carissa Robb: [00:09:55] Yeah. Sure. So, um, and, and the fight goes just kind of a summary score, right? It’s really, [00:10:00] it’s the payment history. That’s the most exposed, like, is there enough income to sustain the existing debt, um, and, and take on new debt? Right. That’s not something we can say with a high level of competence right now because of those factors.

[00:10:14] So the, with mortgage, um, and I’ll just draw a quick parallel prior to 2008. We didn’t really do loan modifications. Um, there was, and, uh, a need for it and you just prioritized your mortgage and you made your payment and you’ve moved on. Um, after the financial crisis, we started to see kind of an explosion of, um, regulatory pressure, consumer, uh, protection laws that were basically requiring us before we were going to move forward.

[00:10:40] Foreclosure exhaust all your options. If you look at, um, The, the state of the auto industry right now, the strategies for mitigating losses for customers that are at risk are mostly between short-term extensions. Um, kind of put the bandaid on, right? See if the borrower can get themselves out of their own trouble, um, [00:11:00] or repo.

[00:11:00] And so there’s, there’s not a lot in the middle ground, uh, between those two, those two bookends. And so there’s, there’s opportunity to just do things a little bit differently by the consumer. Um, and in order to do that, you’ve got to get a little bit more precise on the hardship of that borrower and then their ability to repay.

[00:11:19] So by no means, are we suggesting modify everybody? Um, we know banks are not non-profits, uh, where there there’s pricing strategies. So to return value in return, you know, keep those margins, um, healthy, but there are borrowers in the middle of, um, you know, prior to going to repo, uh, that have the willingness to repay and may need small concessions to return to the ability to repay.

[00:11:45] Yeah. So that’s the modifications and restructuring debt, um, with very sound, you know, parameters and guidelines to kind of establish that affordability, um, can avoid, you know, the, the, the overwhelming volume, just going [00:12:00] into the, into the repo pipeline, um, while values are starting to compress and, and, uh, return to more normal levels.

[00:12:07] So it was just kind of expanding, um, very similar to what we did in mortgage, expanding the analysis, um, and the, the understanding of the different segments of the micro hardships. That might be a portfolio. And if you could

[00:12:21] Joel Kennedy: [00:12:21] help. Yeah. And I, I mean, there’s a structural call to action in my mind. So if I think of a classic, say, hundred to $5 million lender in consumer, you’re going to have some equity and you’re probably going to have some kind of debt that’s going to make up, you know, somewhere between 65 and 85% of each dollar you lend.

[00:12:42] And the covenants that you have within those relationship documents indicate that you’re only allowed to extend a certain number of your customers. You can only have so many delinquent, um, Uh, you have to charge off on a certain day, right? I mean, so these things are limiting factors to your ability to be able to deliver some of these [00:13:00] programs.

[00:13:00] And, um, you and I were speaking earlier or, or trading emails on, uh, Cordray’s letter that he had sent a while back saying, Hey, you know, Here’s kind of a template for how I think a director of manager needs to move forward. And he was talking about like auto repossession moratorium during and post COVID.

[00:13:22] And I sit there and think if I think from a CFO standpoint, I’ve got to provision enough capital within the, uh, Equity side of the, of the business to make sure that if, if I’m going to do these things and I don’t have a concession from my bank lender, you know, I’ve got to provision more capital. My hope is that if, if the CFPB comes out with something stronger saying that we really want to drive a certain edict, that the banks who provide the debt through to the, to the lenders will, will, will also ease up a little bit.

[00:13:57] Um, But then that gets me worried about, you know, [00:14:00] liquidity markets as well, right in the debt markets, you know, are they going to want to sign more new deals nowadays? But, um, anyway, I, I, I say that just articulate that there’s a great deal of uncertainty going on, but within what you are advocating, which is part and parcel of the product is, um, allowing the user to, to, to really define what’s going on.

[00:14:24] Articulate it to you guys do it online, where it’s captured, um, and, and provide some other features that allows the lender to now. Do more analysis with that actual hardship information. Right? So this is, this is to me like a whole new world and a transition, but I love it because it, it, it respects where we are, right.

[00:14:46] Respect

[00:14:47] Carissa Robb: [00:14:47] to where we are. Yeah. And I think, you know, putting blanket anything in place, doesn’t make a lot of sense. You’re asking you’re you’re shifting the problem into a new bucket. So, um, COVID is a classic example. Any natural [00:15:00] disaster response, we tend to reduce the barriers to entry because anything else is cost prohibitive and it compromises speed to market.

[00:15:06] So in with good faith, lenders went out and said, Hey, here’s your one or two month extension, uh, mortgage side. Here’s your six to 12 month forbearance. Get yourself back on track within whatever time allotment was allowed for the relief. Right. So that’s fine. But what that does is without asking the right questions of, um, what is your underlying hardship, um, are you actually impacted by your ability to repay or, or are you taking this relief as kind of an abundance of caution?

[00:15:36] It’s really unclear to understand the volatility that’s coming out of that pandemic. Um, it’s a, it’s a guest right. Of how many customers are going to return to payment. Who’s going to need more, who’s headed to repo. And so I always get a little bit nervous when we talk about blanket moratoriums, um, because it’s the same thing, right?

[00:15:54] You’re, you’re kicking the can. And at some point you’re going to have to address the folks that can [00:16:00] pay and the folks that need to gracefully exit, um, ownership. So that’s where. Having a little bit more, um, process control, certainly compliance framework. Um, that was one thing that I, you could not escape as a mortgage lender, um, or servicer, you know, starting now to develop those programs and say, we’ve we’ve before we just let the days pass, do trigger, uh, send, send a customer to repo.

[00:16:26] We offered assistance. Uh, we engaged with them. We tried to understand, you know, their solvency position and can they repay those are factors that. Um, could help the industry stay. Um, still take a step forward with consumer protection and doing the right thing, but not a drastic, you know, one size fits all.

[00:16:44] If nobody gets repossessed. Um, the other alternative to that is encouraging very transparent, um, exits of ownership, like a voluntary repossession, voluntary time to sell. Uh, those were also features [00:17:00] that didn’t. Um, contribute to like clogged foreclosure pipelines and the last go round and the same thing could happen here and repost.

[00:17:07] So it’s really about giving options, um, giving the borrower a chance to engage, seeing if you can work something out and hopefully if the industry can take steps forward and kind of expanding that collaborative process, um, hosts the immediate attention we can avoid, um, things that that will create more.

[00:17:27] Clogs in the pipeline and more problems by just doing like a moratorium.

[00:17:31] Joel Kennedy: [00:17:31] Yeah. Yeah. I think, I think the critical thing throughout, whether you’re talking about during a, a moratorium or post or whatever, I mean, I think lenders should all be asking themselves, how are we going to keep this customer communicating with us?

[00:17:49] Carissa Robb: [00:17:49] Yeah, there was a really good article, um, this morning, uh, I think it was this morning, um, American banker and, uh, Andy Dubach sheep bank of the West CEO of [00:18:00] bank of the West was talking about how, um, customers have always told us, show me, you know, me. Um, and so that, that kind of comes through like prepare for their needs and, and speak to the consumer.

[00:18:12] Um, You know, through the technology, give them a channel, give them a chance to engage, meet them where they want to be met. Right. And the whole, the whole undertone of that article was about, this is not a temporary problem. This is not a temporary preference to bank, you know, remotely and, uh, electronically there’s been major shifts.

[00:18:31] Um, and consumer preferences for online and mobile banking. And so this is just another, uh, area of innovation. You know, mobile deposits are kicking off. Um, Zelle is kicking off, uh, and seeing major, major increases. This is just another example of, um, introducing technology and like an alternative channel, uh, for customers to tell you what’s going on and get really, and it’s, it’s.

[00:18:54] It’s expensive. You know, if you’re doing that with inbound phone calls and, uh, staffing your call [00:19:00] center, um, people are expensive just to cover the task of answering that call. And they’re even more expensive if they make an error. Um, and somehow cause consumer harm or some sort of financial, uh, fallout.

[00:19:12] So yeah, technology is becoming more critical and more preferred for most of the consumer cases.

[00:19:19] Joel Kennedy: [00:19:19] So I’m going to, I’m going to say something it’s, it’s totally meant to be flattery. Um, so back when I had my auto finance company, I was at, I was at obviously a Northridge customer. Uh, I worked for Northridge now, and they’re the, they’re the sponsor of the podcast, fantastical and management system.

[00:19:33] I had to be part of the team. Um, one of their big integrations is with a company called paychecks. And at the time I was using the traditional merchant services options, but pay X took the merchant services options. And embedded them within a white labeled consumer app. And that app. What we saw was if a customer downloaded the app on their phone, they would, there were more likely to make a payment on the app.

[00:19:59] So a [00:20:00] self-service situation. And we also had chat functionality that is, is to this day it’s, it’s, it’s a core integration with a Northbridge. So it gets posted in notes. So I can control what’s being said, Right. Or I can at least monitor what’s being said back and forth to a customer on a chat and that’s part and parcel of, of what you guys are bringing forth, which is, like I said, at a high level that the kind of user, uh, permission do user engaged.

[00:20:27] Opportunity for them to tell their story in a very safe space. Right. So it’s, it’s online or on their phone or whatever. So they don’t even have to talk to somebody because, you know, that’s the thing that I concern myself with. Sometimes I wonder if sometimes people might have some pride or some shame and, and certainly we we’ve all been there.

[00:20:43] Right. But it’s hard to convey that, that, that empathy. Right. So when you do something like this and you create a framework, it’s like, Hey, I’m in this framework. This is it’s okay. I mean, they built a whole thing around it. Right. So, yeah. I love that. But in [00:21:00] terms of frameworks, let’s talk about your, so you laid out a really nice framework that I think is prescriptive for all of the lenders in the space to look at.

[00:21:10] And I’m just going to ask you to kind of. Pop through it and maybe say a couple things you’ve got, what is it about six. Yeah. Six different things that they can do to plan, to make sure that they’re on the front foot. As we enter into this, this, this upcoming period. Yeah. We don’t know exactly when, but, you know, let’s get our ducks in a row, right.

[00:21:31] Carissa Robb: [00:21:31] Equity plan for plan for it now. Um, and you can always adjust that if you there’s no such thing, especially with the regulatory environment we’re heading into, um, over-planning, over-preparing is not a, it’s not a bad thing when it comes to compliance and self-service strategy. Uh, the, the most challenging one, I always say, start here is your culture, um, just acknowledge it is.

[00:21:51] Do you have a culture that’s willing to, um, expand their risk appetite that. You know, they’re willing to look at restructures. They’re willing to look at voluntary surrenders, [00:22:00] um, start to ask the questions, you know, how, how much emphasis is placed around compliance. You would app CFPB, consumer protection.

[00:22:08] Um, it’s not that obvious. Um, and some of the responses may be surprising, uh, especially if there wasn’t a joint, you know, mortgage servicing and auto servicing relationship there. So starting with culture, always, always important. Um, policies, uh, they’re acknowledged the fact that it is, um, intimidating to introduce a new last mitigation strategy.

[00:22:31] Uh, introducing anything new is, um, it can be intimidating, uh, but, but there’s gradual, um, sound ways to roll that out. And a lot of people, uh, start by saying, well, you know, an economic downturn is not the time to try something new. When it comes to loss mitigation, neither is a performing market because you don’t have the need.

[00:22:51] And so your, your, um, prioritization and your allocation of cash is going to go to front-end. Um, so this is a really good time to start [00:23:00] expanding, um, uh, policy expanding solutions, you know, setting your thresholds. What, what is an affordable threshold? What is the floor term? If you do want to modify. Um, who is excluded, who’s included, um, all of those things, just start to get the conversation going in a very, uh, kind of crawl, walk, run capacity.

[00:23:20] Joel Kennedy: [00:23:20] I’ll throw in just that your control environment is important in that aspect as well. Because if you provide certain forbearance to one individual and not to another, you need to have a solid leg to stand on.

[00:23:30] Carissa Robb: [00:23:30] Absolutely. So, um, any policy and this is, I think I mentioned this in the beginning consumer protection.

[00:23:36] Um, it used to be, uh, Not frustrating, but it was challenging, um, to have that kind of pressure with you adapt, uh, while you’re trying to run a multi-billion dollar portfolio, it’s challenging. Um, and, and people should feel comfortable saying that. Um, it also starts to, again, going back to the culture piece, right.

[00:23:57] Become second nature to, [00:24:00] to analyze potential downfalls, potential exposure, potential negative impact, um, as just part of your baseline, you know, when you’re creating a policy, uh, to your point, you’re, you’re watching for unintentional bias, unintentional, disparate impact, and just really pulling that thread and having conversations openly.

[00:24:17] Um, not being afraid to just kind of assess like, Hey, are we, are we making sure that this is all inclusive? Are our restrictions, um, fair and, and avoiding the kind of disparate treatment that can get folks into trouble, um, which is, you know, it leads right into the consumer education. Um, there’s most of the CFPB complaints.

[00:24:38] Uh, right now, especially around a wrongful repossession, um, have to do with borrower confusion. So is there whatever your process is, do you use, do your employees understand it? Do your consumers understand that? Do you understand that? Could you, could you explain it in layman’s terms to your neighbor, um, and feel good about the product that you’re offering?

[00:24:59] Um, so [00:25:00] consumer education is a huge part of it. Uh, the, the, the next few steps are really around, um, understanding the financial side, um, having adequate tracking, having adequate technology so that you can reduce any manual inputs, um, and then really being careful and intentional of, uh, how to project, you know, with the reasonable assumptions and reasonable test data.

[00:25:22] Um, what that outcome is going to look like by introducing a new program. Uh, and there, there are, um, gradual ways. It doesn’t have to, you don’t have to go from zero to a hundred. You can kind of take your time and say, we’ve got a problem here. You know, we’ve got folks that are headed to repo and th but we’ve got a lot of right party contacts to our collections channel.

[00:25:41] Like they’re asking for help. They’re calling in and we don’t have a solution. And you just start to peel back the layers and ask the right questions of what if we did this. You know, and it just, um, makes the process of introducing something new a little bit less scary because you’re starting from the place of solving a real problem.

[00:25:59] Uh, not [00:26:00] only on your balance sheet, but, um, for your, for your consumers.

[00:26:03] Joel Kennedy: [00:26:03] Yeah, and I love, I love the process that you created, where it does take you through questions for people that may say Jesus is a daunting thing. Like what questions do I ask? I don’t want to be too intrusive. Um, you guys already have a lot of that figured out or all of it figured out, so it really does make it easy, um, to kind of go through that, that whole Q and a process.

[00:26:23] And I personally love it, obviously because it takes your, um, valued employees. Who are going through these dialogues and saying, you know what, they can do it themselves. They really can’t do it themselves. You’ll probably get a higher response rate. You’ll probably get better performance, but then the whole Shangrila at the end is now we have some historical data that we’ve captured that as we look at valuing the portfolio likeliness to default timing to default, um, you can start building cohorts.

[00:26:58] That are very meaningful, [00:27:00] that you can then put into some type of a model and even feed, even feed to inform the origination model. And I think that’s really at the end of the day, the power of what you’re proposing. Yeah,

[00:27:12] Carissa Robb: [00:27:12] absolutely. So it’s why we, um, it’s why we started down the path constant. Plus we, we knew we had, you know, Restrictions of a minimum FICO and how much we could have within our lending portfolio.

[00:27:23] Um, you know, very various, uh, covenants and restrictions on what we could lend. So one of our major goals before COVID hit was how do we, um, Soundly by deeper into our credit box. Um, how do we lend to more people? Because we were lending with, uh, um, contractors and so our approval rate meant retention of business, um, and same thing without it, right?

[00:27:47] The goal is market share. So how do we continue to be able to give these loans out to folks that need them, but also, um, you know, let our, our, uh, our partners feel comfortable with. The credit quality. Um, and [00:28:00] one thing we wanted to do was say, okay, well, If we, if we have this program on the backend one, we can mitigate the loss and improve portfolio performance because we can be more granular and more precise, um, with understanding the volatility of our own books.

[00:28:14] So I can, I can report on how many folks that applied for a hardship or unemployed and not receiving benefits. Um, and then the second part of that was. Let’s say we’re looking at open banking, data and number of NSF fees. Well, let’s watch the performance of that attribute against a phyco against a back-end DTI and see how they perform, and then use that to supplement our credit origination policy.

[00:28:38] So it becomes very cyclical where today the relationship between origination and servicing and then collections and repo tends to be more linear. Um, you start to really leverage, uh, new pieces of information. Especially for borrowers under stress. Um, and, and you informed that, that credit policy. So it becomes really cyclical and, um, kind [00:29:00] of an evolving practice instead of just, you know, originate, hope it performs and then deal with it.

[00:29:06] You know, first lost is the best loss kind of approach. Um, it’s just expanding and it’s evolving as taking a step forward from that.

[00:29:14] Joel Kennedy: [00:29:14] I love it. If we learned anything from this year, it’s you gotta be intentional with your life with work and, you know, you’re advocating be intentional. Uh, think strategically about your loss mitigation strategy.

[00:29:25] Think about your credit policies and how that’s going to feed into the need for different, um, loss, mitigation efforts. And, and I mean, that’s, that’s kinda my, my takeaway Carissa

[00:29:38] Carissa Robb: [00:29:38] there’s there’s consumers at the, at the center of this, um, there’s obligations to shareholders, for sure. Uh, um, but, but it’s not one or the other anymore.

[00:29:48] The more, we try to challenge our approach, customer centric, customer protection, but also balanced expectations for return. Just feel comfortable saying that like w we’re doing both, um, I think that’ll go a [00:30:00] long way in the regulatory environment that we’re heading into. Um, and you know, hopefully we’ll, we’ll start to.

[00:30:06] Progressed the industry as a whole, uh, you know, for, for banking and, and, um, financial services, just, just in general.

[00:30:14] Joel Kennedy: [00:30:14] Yeah. It’s a good time. Cause everybody’s in the same boat. So I think you’re going to get a good ear, whether it’s from the banks, uh, regulators, uh, I think, uh, remains to be seen, um, Carissa, this is, this has been great folks.

[00:30:25] Is Chris Rob she’s the president and COO of constant. What if people want to learn more or, you know, kind of pick your brain a little bit, um, What, what are, what are, what’s the best way for folks to connect with you guys?

[00:30:38] Carissa Robb: [00:30:38] So our website is Um, there’s a ton of information there. I am super passionate about the topic.

[00:30:46] It’s just something I really, um, enjoy. I like helping, uh, people that are really interested in progressing their strategy. So, um, certainly email me. It’s um, C Rob, C R O B And I’m always [00:31:00] a phone call or an email away. So. Happy to happy to help folks just talk

[00:31:03] Joel Kennedy: [00:31:03] it out. Outstanding and folks keep, keep your eye out for the article in non-prime times.

[00:31:09] Um, not to be missed it’s it’s, uh, I mean, it’s pretty much what we spoke about today. You have a little bit more, um, quotes and data in there, which I think is great for that population that appreciates that I know I’m on and I think you are too, but, um, Well, outstanding. Well and happy holidays to you, Krista.

[00:31:26] Thank you so much for joining us on the podcast and, uh, I wish you and the constant folks, a fantastic 2020.

[00:31:33] Carissa Robb: [00:31:33] Awesome. Same to you. Thanks for having me take care.

[00:31:37] Joel Kennedy: [00:31:37] The consumer five podcast has been brought to you by Northbridge loan software. That accelerates change. We’d also like to thank the national automotive finance association.

[00:31:47] The only trade association, exclusively serving the non-prime auto financing industry. [00:32:00]

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