Steer Clear How Credit Unions Help Car Buyers Avoid Predatory

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							Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   1
       Table of Contents

    Preface ................................................................................................ i
    Acknowledgments ......................................................................ii
    Executive Summary .................................................................. 1
    Method ............................................................................................... 3
    Market Analysis ............................................................................ 4
    Lessons Learned ......................................................................... 7
    Other Observations .................................................................22
    Concluding Comments ........................................................24
    Next Steps ....................................................................................25
    References ...................................................................................26
    About the Author ......................................................................27
    Appendices
        Survey: Invitation Letter ................................................. 28
        Survey: Results and Verbatim Comments............. 29




      This research was funded by the Annie E. Casey Foundation. We thank
    them for their support but acknowledge that the findings and conclusions
    presented in this report are those of the authors alone, and do not
    necessarily reflect the opinions of the Casey Foundation.



Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  Preface

  Founded in 1948, the primary mission of the             As the philanthropic and social responsibility
Annie E. Casey Foundation is to foster public          leader of America’s credit union movement, NCUF
policies, human-service reforms, and community         raises funds, makes grants, manages programs,
supports that more effectively meet the needs of        and provides education empowering consumers
today’s vulnerable children and families. In pursuit   to achieve financial independence through not-
of this goal, the Foundation makes grants that help    for-profit credit unions. Donations to NCUF
states, cities, and neighborhoods fashion more         enable credit unions to help their members reach
innovative, cost-effective responses to these needs.    life-changing goals. Through NCUF grants and
  One of the Annie E. Casey Foundation’s               programs, credit unions create greater access to
investment areas is expanding social and economic      affordable financial services, provide widespread
security for families in poor communities. In 2006     financial education, and empower more consumers
the Casey Foundation expanded the focus of its         to save, build assets, and own homes.
work on payday lending and check-cashing to fund          To further credit unions’ efforts to serve
research on auto lending. The Casey Foundation         consumers with low wealth and modest means,
funded a report by Remar Sutton of the Consumer        NCUF in 2007 began the national expansion of
Task Force for Automotive Issues. Car Financing        REAL Solutions® as its signature program. Upon
for Low and Moderate Income Consumers assessed         reviewing the Annie E. Casey Foundation research
this key component of the auto finance market.          on auto lending, NCUF proposed the current
  In addition, the Casey Foundation funded a           project, which examines a full range of credit union
documentary and discussion guide entitled Pursuit      innovation in non-prime auto lending.
of the Dream: Cars & Jobs in America, to explain the      This project is jointly funded by the Annie E.
importance of affordable, reliable transportation       Casey Foundation and NCUF. The Aspen Institute
for building the economic success of low-income        helped facilitate the work under this grant.
families and their communities.                           This project brought to light both commonly held
  Around the same time, a separate report              assumptions and unclaimed innovations.
demonstrated how one credit union successfully            I would like to express my appreciation to the
serves borrowers with low credit scores. University    Annie E. Casey Foundation and the National
Federal Credit Union’s Analysis of Sub-Prime           Credit Union Foundation for providing the funding
Lending Program presented a case study of a credit     for this report. Special thanks are due to Steve
union in Austin, Texas, using a pure risk-based        Delfin, Executive Director of NCUF, for his early
lending technique.                                     recognition of the critical importance of this
  These initiatives led to two meetings at The         issue, and to Irene Skricki, the Annie E. Casey
Aspen Institute during the first half of 2007 to        Foundation’s Program Manager for Assets and
bring together parties interested in collaborating     Savings, for her ongoing insights and support.
on ways to provide affordable car financing to
more low- and moderate-income borrowers. One           William Myers,
of the participants was the National Credit Union      Field Coach, REAL Solutions®
Foundation (NCUF).                                     Senior Fellow, The Aspen Institute




                                      Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   i
      Acknowledgments

      This project would not have been possible without the credit union industry executives, service providers,
     and friends of credit unions listed below, as well as the 251 credit unions that provided survey responses.
     Your inventiveness, enthusiasm for service, and willingness to participate in this project is sincerely appreciated.

     Shelly Berryman, Director of Member Advocacy                   Carolyn Hayden, Managing Partner
     Schools First Federal Credit Union                             MGH Consulting, LLC
     Santa Ana, CA                                                  Springdale, MD
     Larry Blanchard, Senior Vice President—Special Projects        Vicki Joyal, Field Coach—REAL Solutions®
     CUNA Mutual Group                                              Madison, WI
     Madison, WI
                                                                    Lois Kitsch, National Program Manager—REAL Solutions®
     Tom Boos, President/CEO                                        National Credit Union Foundation
     Billings Federal Credit Union                                  Washington, DC
     Billings, MT
                                                                    John Lass, Senior Vice President—Strategy & Product
     Steve Bosack, Deputy Director                                  Development
     National Credit Union Foundation                               CUNA Mutual Group
     Washington, DC                                                 Madison, WI
     Paul Budvidas, Regional President                              Kirsten Moy, Director—Economic Opportunities Program
     Walkaway USA                                                   The Aspen Institute
     Irving, TX                                                     Washington, DC
     Bob Falk, President/COO                                        Jeffrey Purvis, National Impact Center & Database Manager
     Purdue Employees Federal Credit Union                          National Credit Union Foundation
     West Lafayette, IN                                             Washington, DC
     John Flynn, President/CEO                                      Betty Saiz, Vice President—Indirect Lending
     Open Lending Inc./Lenders Protection, LLC                      U.S. New Mexico Federal Credit Union
     Austin, TX                                                     Albuquerque, NM
     Brooke Gilchrist, National Marketing Manager                   Linda Stephens, Vice President—Consumer Lending
     Enterprise Car Sales                                           Wright-Patt Credit Union
     St. Louis, MO                                                  Fairborn, OH
     Barbara Goodwin, President/CEO                                 Corey Stone, CEO
     Fitchburg ME Federal Credit Union                              PRBC (Payment Reporting Builds Credit)
     Fitchburg, MA                                                  Annapolis, MD
     John Goodwin, Senior Vice President—Commercial Products        Pete VanGraafeiland, Manager—Loan Retailing and Servicing
     CUNA Mutual Group                                              Coastal Federal CU
     Madison, WI                                                    Raleigh, NC
     Yulanda Grant, Executive Administrator                         Jim Wagy, Senior Vice President/Chief Operating Officer
     National Credit Union Foundation                               Tropical Financial CU
     Washington, DC                                                 Miramar, FL
     Douglas Grout, Senior Vice President—Credit Union Operations   Margy Waller, Executive Director
     SELCO Community Credit Union                                   The Mobility Agenda
     Eugene, OR                                                     Washington, DC
     Bill Hampel, Chief Economist
     Credit Union National Association
     Washington, DC


ii   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
    Executive Summary

  Despite rapidly rising gas costs, the vast          unions are now struggling to make loans.
majority of Americans (88%) continue driving          Used-vehicle loan growth rates have dropped
to work. A Brookings Institution Policy Brief1        considerably in the past three years after a
lamented that “fewer than 5% of workers               decade of growth rates in the 10% to 20% range.
took public transportation to work.” In many          The mortgage market has slowed, but there are
situations (e.g., single-parent households),          plenty of needy consumers wanting to buy a car.
public transportation is not available or is            As other lenders tighten their standards or exit
not practical for taking children to daycare or       the non-prime market altogether, a significant
school and arriving to work at a designated           opportunity exists for credit unions to meet
time, at a location far from home. Cars can           the needs of consumers whose options have
provide convenience, flexibility, safety and the       narrowed and may be pulled to predatory
opportunity for lower-income people to work           lenders. Those credit unions with strong capital
for employers that are not located near public        positions and stable balance sheets are in a solid
transportation.                                       position to take advantage of the opportunities
  Thus, an important strategy for strengthening       that this market offers, even during the current
economic mobility and our economy is to ensure        economic slowdown.
that workers with low wages and/or low credit           Credit unions’ programs and techniques for
scores are able purchase reliable, affordable cars.    making vehicle loans may not be working as
  Non-prime auto lending represents a                 well as they should. Techniques such as “See
substantial nearby opportunity for not-for-profit      Us First” have proven to be only modestly
credit unions to expand their markets, build net      successful for securing loans before members
income, and attract new loyal members by giving       head to showrooms and become exposed to
them a substantially better deal.                     finance and insurance (F&I) salesmen. Indirect
  This research report identifies the lending          lending has created loan volume, but at the price
techniques by which credit unions are making          of having dealers represent the credit union as
large and sustainable inroads into the non-prime      the member’s primary contact. Credit unions
auto market. The findings are presented as seven       uniformly report that indirect lending leads to
lessons.                                              single-service members. Auto loan recapture
                                                      programs have shown some success, but again
Market Opportunity                                    at the price of ceding the initial relationship to
  The market for non-prime used auto loans            dealers and other lenders.
is large and has not historically been served
by most credit unions. This is unfortunate as         Time for Change?
some borrowers are subject to excessive charges         Perhaps it’s time for credit unions to change
and credit unions are missing a large and             it up—to enter new markets and employ new
economically viable service opportunity.              models in order to increase and strengthen their
  Consider this: Over 40 million used vehicles        vehicle loan portfolios.
are sold each year in the U.S.—2½ times the             Some credit unions across the country are
number of new vehicles sold. Eight million            successfully implementing non-prime used
(20%) of these cars are sold to low- and              auto loan programs. Some are revising their
moderate-income borrowers.2 Many of these             programs after a less-than-successful launch,
borrowers end up buying their cars through            while others are just entering this market.
predatory lenders such “buy-here-pay-here” and          Sadly, given that credit unions account for only
“auto title” outlets.                                 5% of non-prime used auto loans, it becomes
  While vehicle lending has traditionally served      obvious that the majority of credit unions are not
as credit unions’ “bread and butter,” credit          serving this market.
1
                                                        Why not? Potential reasons why credit unions
  Margy Waller, The Mobility Agenda, “Brookings       are not serving borrowers with low credit scores
                        ”
Institution Policy Brief. 2000.                       include uncertainty and unfamiliarity, downside
2
  Remar Sutton, Consumer Task Force for Automotive    loss potential, lack of data about this market,
Issues, “Car Financing for Low and Moderate Income    board apathy or reluctance, and regulatory
            ”
Consumers. April 2007.                                concerns.


                                        Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   1
Why Serve this Market?                        Seven Lessons                        can effectively steer members
                                                                                   away from modern loan sharks.
  So why should credit unions lend              The information derived from
to more low- and moderate-income              credit unions and from suppliers
borrowers? Two principal reasons:             that have developed products/        LESSON 4: Employ a “hard
  1) It’s good business. Survey responses     services to meet the needs of this   close” to cement bonds
that form the basis of this report            market can be summarized in the      with members.
demonstrate examples of used auto             following seven lessons learned:
                                                                                     Verify information, educate the
lending programs that have proven
                                                                                   borrower, and reinforce the value
successful — both in terms of providing       LESSON 1: Non-prime                  of membership when closing
affordable car ownership for non-prime
                                              used auto lending is a               every loan. This process of
borrowers and sustainable business
strategies for credit unions.                 financially viable line of            documentation, education, and
                                              business.                            loyalty building provides a solid
  2) It’s credit unions’ mission. Federal
                                                                                   defense against the increased
credit unions and many state credit             Given the pervasiveness of         delinquency that comes with
unions are chartered with a statutory         lenders charging excessively         moving down the credit score
mission to serve “people of modest            high rates in this marketplace,      scale.
means.” And even where state credit           credit unions are able to price
unions do not have this mission               non-prime loans for risk and
expressly written in their charter, it is     effort and provide members a          LESSON 5: Insure borrowers
implicitly written in their history. All      better deal. Price + a lender that   against events out of the
credit unions in the U.S. are member-         has the borrower’s best interest     realm of their control.
owned, not-for-profit cooperatives             in mind = a better deal. Credit         From credit disability and credit
established as part of a movement to          unions’ non-prime used auto          life to guaranteed asset protection,
provide consumers with more affordable         loan rates, while necessarily        mechanical breakdown insurance
alternatives to the for-profit banking         higher than credit unions’ prime     and debt cancellation, a successful
industry and to put predatory loan            rates, are significantly lower than   low-score auto loan program
sharks out of business. Whether this          what borrowers could receive         will include protections for the
mission is written or unwritten, all credit   from other lenders.                  borrower as well as the credit
unions to some extent are expected by                                              union.
lawmakers, regulators, consumer groups,
foundations, the media, and the public
                                              LESSON 2: Reduce the
to help people who are not being served       underwriting gap by                  LESSON 6: Export risks by
by banks and who are vulnerable to            transferring traditional             using available loan loss
predatory lenders.                            character lending                    insurance products and
                                              techniques into an                   guarantees.
Learn from Innovators                         automated decision-                    Default and collateral
  Now the question is: Can credit unions      making process.                      protection insurances exist to
viably lend to more low- and moderate-                                             minimize the credit union’s risk
                                                Old fashioned, high-touch
income borrowers in a safe and sound                                               with non-prime borrowers.
                                              character underwriting is
manner?
                                              effective for non-traditional
  This project focused on finding the
answer from innovators. And it became
                                              borrowers, but the process needs     LESSON 7: Keep in touch
                                              to be more fully automated and       with borrowers by allocating
clear that with sufficient information and
                                              efficient in order to effectively
properly designed programs, the answer                                             resources to monitor and
                                              compete in this marketplace.
is a resounding “Yes!”                                                             collect the loan at the first
  Our surveys and interviews revealed                                              sign of trouble.
many examples where credit unions have        LESSON 3: Get in front
developed innovative loan products and        of dealers by assisting                It’s critical for credit unions to
                                                                                   modify their existing collections
features to meet the needs of non-prime       members in finding cars.
used auto loan applicants—without                                                  processes to include “proactive
                                                Whether through an                 collection.” This is an aggressive
sacrificing financial safety and soundness.
                                              agreement with a select few          but not abusive practice.
  All of the credit unions and suppliers
                                              dealers, an online car buying          Credit unions are able to
profiled in this report encourage more
                                              service, or by sponsoring used       successfully enter (or re-enter)
credit unions to engage in non-prime
                                              car sales, this is a good way to     the non-prime auto lending
used auto lending. Our sources invite
                                              maintain direct contact with         market by incorporating the
other credit unions to consider replicating
                                              borrowers and to ensure that         lessons above into loan programs
or adapting their products to serve non-
                                              members get good deals on            designed specifically to meet the
prime borrowers across America.
                                              reliable used cars. Credit unions    needs of emerging markets.
2   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  Method

  How Credit Unions Help Car          credit unions that were doing         What Do We Mean?
Buyers Avoid Predatory Loans          “innovative work with low credit
                                                                              For purposes of this report, the
identifies credit union lending        score auto borrowers.” So the
                                                                            definition of:
techniques that can successfully      population of interest for this
                                                                              u “Low credit score” is a FICO
expand auto lending to non-           project is limited to credit unions
                                                                            score (Fair Isaac Corporation’s
prime borrowers. The research         that are implementing innovative
                                                                            credit score) below 600.
contained within this report was      approaches to D and E paper auto
                                                                              u “D-paper” refers to loan
derived using qualitative methods     loans. Each e-mail included a
                                                                            applicants with FICO scores
and a self-selected sample. It is     link to the online survey.
                                                                            between 550 and 599.
not statistically representative        The survey instrument
                                                                              u “E-paper” refers to loan
of all credit unions – but it does    consisted of six multiple-
                                                                            applicants with FICO scores
showcase innovative product           response questions, each with a
                                                                            below 550, with thin credit files
features and practices that not-      set of pre-determined response
                                                                            or no credit records at all.
for-profit credit unions are using     categories, plus an “other” field to
                                                                              u “Low-to-moderate income”
to assist members who might           capture responses that didn’t fit
                                                                            and “low wage” refers to
not otherwise qualify for vehicle     neatly into one of the categories.
                                                                            households with annual incomes
loans.                                The six questions covered
                                                                            of less than $40,000.
                                      underwriting, car sourcing, risk
                                                                              u “Emerging markets” is used
Targeted Auto Loan Survey             mitigation, insurance, marketing,
                                                                            in this report to refer to growing
  In mid-December 2007,               and partnerships. In addition,
                                                                            markets that have not been fully
an invitation to take part in         a final question asked whether
                                                                            served by insured depositories:
the National Credit Union             the respondent’s low credit
                                                                            immigrants, youth, the unbanked,
Foundation’s (NCUF’s) Auto            score auto lending program
                                                                            and low-income.
Loan Survey was e-mailed to the       was successful, and to describe
                                                                              u “Non-prime” is used to
entire group of nearly 400 credit     lessons learned.
                                                                            redefine and emphasize the
unions that have participated           By March 10, 2008, a total of
                                                                            business opportunities that
in NCUF’s REAL Solutions®             251 responses had been received
                                                                            exist beneath “prime” and
program to provide products and       from credit unions of all asset
                                                                            above “sub-prime.” Non-prime
services to low-wealth and low-       sizes, fields of membership, and
                                                                            has historically been lumped
to-moderate-income households.        geographic service areas.
                                                                            together with sub-prime—and
An identical invitation was                                                 thus depicted as a potentially
e-mailed to the entire group          In-Depth Interviews                   dangerous market for regulated
of Credit Union Development             In-depth telephone interviews       lenders to enter. Non-prime
Educators (CUDEs), nearly 800         were then conducted with a            today is not exclusive to “low-
graduates of NCUF’s immersion         dozen credit unions representing      to-moderate income” or “low-
training in cooperative principles    the various innovation areas          wage” borrowers. Non-prime
and credit union values.              identified in survey responses.        can also include middle-income
  In addition, on January 18,         These interviews gathered             borrowers with other credit
2008, Credit Union Times              additional information about          issues. Given the current credit
published a full-page article         their non-prime vehicle               crunch and the importance
about the project as well as the      loan programs. Many of the            of obtaining credit to ensure
survey URL.                           interviewed credit unions are         transportation to work sites, all
  Finally, on February 10, 2008, an   profiled in this report.               non-prime consumers could also
invitation to complete the survey       Finally, in-person interviews       be considered “people of modest
was e-mailed to 12,000 credit         were conducted with vendors           means.”
union executives representing all     that were frequently identified
8,400 U.S. credit unions.             by survey respondents
  In each instance, the invitation    and interviewees to gather
from William Myers, who was           information about their product/
also serving as a REAL Solutions®     service offerings related to non-
Field Coach, specified that            prime vehicle loans.
the survey was designed for


                                      Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders     3
                       Market Analysis

                       Similar to the lack of affordable     recent years, as more jobs have       prime mortgage loan debacle
                     child care, lack of transportation     moved to the suburbs, access to a     has caused the overall mortgage
                     is a common problem facing low-        car creates greater access to jobs.   market to slow. Many homes
                     wage workers trying to get—and         Reliable, flexible transportation      decreased in value and as a result,
                     keep—a job. Improving job              allows consumers to earn more,        the home equity market has
                     opportunities for all Americans        to get better jobs, and to have       diminished as well.
                     is crucial to strengthening our        more choices in terms of housing,       Real estate markets are likely
                     communities. Unfortunately,            schools, and activities. In fact,     to remain soft or to become
                     not owning a car is increasingly a     access to a car is positively         unstable in the coming years.
                     barrier to economic mobility.          correlated with an increase in        If credit unions shift now, well
                       According to Margy Waller,           work hours and higher earnings.   ”   collateralized used auto lending
                     executive director of The Mobility       Thus, an important strategy for     could grow steadily.
                     Agenda:                                strengthening economic mobility         The used auto loan market will
                       “Transportation is the second-       and our economy is to ensure          be “hot,” according to CUNA
                     largest consumer expenditure           that workers with non-prime           Economist Steve Rick in a May
                     after housing. Most American           credit can purchase reliable,         2008 Credit Union Magazine
                     workers (88%) drive to work.           affordable cars.                       article3. And “even in a down
                     Public transportation—when               So, what is the fit between          economy, people still have to buy
                     available—takes double the time        not-for-profit credit unions,          cars,” reasons Barry Rose, Vice
                     of driving, and can be unreliable      car-buying, and non-prime auto        President of Insurance and Sales
                     and unpredictable. In 2000,            lending?                              for Citadel Federal Credit Union’s
                     less than 5% of employees used                                               indirect lending credit union
                     public transportation to get to        Used vs. New                          service organization, Member
                     work, mainly in three large cities.      First of all, a huge opportunity    Financed Autos, LLC.
                     Transportation is key to finding        exists for credit unions to
                     and keeping employment. In             increase their market share           Loans vs. Investments
                                                            and portfolio of used car loans.        More important in the long
FIGURE 1                                                    Consider that over 40 million         term—and in any economic
                                                            used vehicles are sold each year      climate—will be finding ways
Distribution of Credit Union Loans                          in the U.S.—more than twice the       to permanently rebuild credit
(as of March 2008)                                          number of new vehicles sold. At       unions’ loan-to-share ratio.
                                                            year-end 2007, used auto loans        Credit unions’ very name clearly
                                                            represented 12% of credit union       indicates their purpose as
                               Home Eqity
             Second Mortgage     6.9% Other
                                                            assets: $92 billion.                  cooperative lenders rather than
                 10.5%                                        Figure 1 depicts the distribution   as simple savings or investment
                                          4.6%              of credit union loans as of March     clubs. Yet perhaps in part
First Mortgage                                              2008. Note that the credit union      because credit unions have not
   Adjustable                                    New Auto   loan portfolio dollar distribution    tapped their potential to serve the
     11.7%                                        15.7%     of used auto (17%) versus new         non-prime auto lending market,
                                                            auto (16%) loans is nearly            credit unions’ loan-to-savings
                                                            identical.                            ratio has hovered between 70%
                                                              With an average loan amount         and 80% for decades. This
                                                            of roughly $11,000, it takes          means most credit unions could
                                                            considerably more used auto loans     reallocate significant funds from
First Mortgage                               Used Auto      to match the dollar volume of         investments into productive
      Fixed                                   16.8%         new auto loans. But the potential     lending programs.
     23.6%                                                  market of used auto loans is also
                           Unsecured
                             10%                            more than twice as large.             Credit Union Auto Loans Skidding
                                                                                                    Eight million used cars (20%)
Source: CUNA Economics & Statistics’ Monthly                Real Estate vs. Vehicles              are sold to low- and moderate-
Credit Union Estimates                                        After many years of solid real      income borrowers. Credit unions
                                                            estate loan business, the sub-        captured 15% of the total U.S.

                 4   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
auto finance market in 2007.           interest rates and accept loans of    pricing, underwriting, and risk
But credit unions’ market share       shorter duration. ”                   management.
for non-prime loans is a mere           An Automotive Fleet article6
5%. Sub-prime lenders (60%)           reports:                              Concerned Consumers
and banks (30%) dominate the            “Banks are reluctant to lend,         Yet today there are fewer
market.4                              even as their cost of funds           options available for non-
  For the past three years, credit    declines, because they are short      prime borrowers—those whose
unions’ used auto loan growth         on liquidity, are more risk averse,   livelihoods could depend on a
rates have averaged less than 1.7%.   demand a higher risk premium,         lender who is willing to give them
(See Figure 2.) Credit unions         and need to increase profits to        a chance. Economic uncertainty,
would certainly benefit from a         rebuild balance sheets. Also,         high food and energy prices, and
jump start in used vehicle loans.     more lenders are putting caps
                                      on how low a FICO score they’re       4
                                                                              Remar Sutton, Consumer Task Force
Potential to Accelerate               willing to fund, often above the      for Automotive Issues, “Car Financing
  If credit unions would choose to    threshold of subprime borrowers.  ”   for Low and Moderate Income
                                        Yet another Automotive News7        Consumers. April 2007. 5 Donna
                                                                                       ”
approve loans for members with                                              Harris, “Lenders shun subprime
FICO scores below 600, their          article reports that lenders
                                      are adjusting their sub-prime                ”
                                                                            market, Automotive News. February
potential used auto market would                                            18, 2008.
immediately expand by 15%.            strategies by making fewer
                                                                            5
Furthermore, if credit unions         underwriting exceptions, working        Donna Harris, “Lenders shun
                                      to acquire more prime borrowers                        ”
                                                                            subprime market, Automotive News.
could find a way to underwrite                                               February 18, 2008.
borrowers without FICO scores,        to balance the risk of non-prime
their non-prime market potential      borrowers, and tightening loan-       6
                                                                              Mike Antich, “Subprime Crisis
would grow by an additional 40%.      to-value ratios.                                                         ”
                                                                            Metastasizes to Fleet Resale Market,
                                        Credit unions can fill the           Automotive Fleet. April 21, 2008.
Narrowing Options                     void in the non-prime market          7
                                                                             Rosland Briggs Gammon, “Lenders
                                      in ways that are financially                                                  ”
                                                                            adjust subprime strategies to ease risk,
  Unfortunately, the options          viable—with appropriate               Automotive News. November 12, 2007.
available to consumers with non-
prime credit have narrowed—
both with respect to the number         FIGURE 2
of lenders willing to approve
these loans, as well as the loan        Distribution of Credit Union Loans
terms. Fallout from the sub-            (as of March 2008)
prime mortgage crisis is causing
some lenders to tighten standards       25
and step back from making non-
prime loans.
  In January 2008, more than 4%         20
of sub-prime auto loans were
60 or more days delinquent,             15
according to Fitch Ratings.
This is an increase of 43% from
January 2007 and the highest            10
in 19 years. A recent article in
Automotive News5 reports:                5
  “The credit crunch is forcing
many would-be consumers to buy
cheaper models, or purchase a            0
                                             ’94 ’95 ’96 ’97 ’98 ’99 ’00 ’01 ’02 ’03 ’04 ’05 ’06 ’07
used vehicle instead. If customers
with shaky credit can get loans
at all, often they must make a          Source: CUNA Economics & Statistics’ Credit Union Report, Year-end 2007
bigger down payment, pay higher

                                      Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders           5
FIGURE 3
Consumer Concern About
Ability to Obtain Credit
  Credit has already Not sure Extremely Concerned
    been affected      7%            10%
         4.2%                                                   u those from Southern states;        the dealer’s entire vehicle cost.
                                               Somewhat         u consumers who categorize           Then the dealer adds financing on
                                               Concerned       themselves as a race/ethnicity        top. For example:
                                                 23.4%         other than white.                       u The dealer purchases a used
                                                                 GDNAuto President Michael           car with 100,000 miles for $1,000.
                                                               Sheridan said the survey                u The buyer is asked to put
                                                               “highlights the continuing need       $1,000 down and finance $5,000.
                                                               to offer lending to a number             u If the buyer misses even one
                                                               of cash-strapped segments.” A         payment by one day, the car is
                                                               majority of credit unions are in a    repossessed.
Not concerned at all                                           position to do so in ways that will     Buy-here-pay-here dealers
      55.4%                                                    benefit new members as well as         follow a standard operating
                                                               their credit unions.                  model to turn over each car five
Source: Synovate/GDNAuto Survey of Consumers,                                                        times per year.
October 2007                                                   Predatory Competition
                                                                 Many of those who compete           Opportunities for Credit Unions
                       less access to credit have caused       with credit unions in the non-          A review of the non-prime
                       some consumers to worry about           prime auto market are doing           used-car loan market reveals:
                       their creditworthiness.                 borrowers no favors. The                u Consumers with non-prime
                         An October 2007 survey8               predatory nature of “buy-here-        credit scores need (and want)
                       commissioned by GDNAuto                 pay-here” and “auto title” lending    to own cars in order to improve
                       revealed that one in three              has been documented in the            their economic situations;
                       consumers are concerned that            Aspen Institute’s 2007 report,          u Credit unions need and
                       fallout from the sub-prime              Car Financing for Low and             should want to make more car
                       mortgage crisis will affect their        Moderate Income Consumers.            loans, especially in this slow-
                       ability to obtain credit for              The auto title loan process         growth economic environment.
                       “something like a car loan.” Even       involves the borrower driving           u There is considerable room
                       more disturbing: 4% of survey           the vehicle to the title broker       for credit unions to improve their
                       respondents reported that their         for the purpose of pawning the        market share of the vehicle loan
                       ability to obtain credit “has           title but retaining the car. Often,   market and to jumpstart used
                       already been affected.” These            the borrower must present             vehicle loan growth.
                       survey results are illustrated in       the vehicle’s key to the lender         u As other lenders tighten their
                       Figure 3.                               to facilitate repossession, if        standards or exit the non-prime
                         As would be expected, some            necessary. Some states require        market altogether, a significant
                       groups of consumers are more            the borrower to sign a power of       opportunity exists for credit
                       likely to be worried than others.       attorney form so the lender has       unions to meet the needs of
                       Those most worried about their          the right to transfer the vehicle     consumers whose options have
                       ability to obtain credit for a car      title to the lender if the borrower   narrowed and may now be
                       loan include the very groups of         defaults on the loan. In other        limited to predatory lenders.
                       people likely to possess low or no      states, the borrower sells the          u Those credit unions with
                       credit scores:                          vehicle to the title lender in a      strong capital positions and
                         u consumers 18 to 34 years of         sale/leaseback arrangement.           stable balance sheets are in a solid
                       age;                                      Buy-here-pay-here independent       position to take advantage of the
                         u those who are not married;          used auto lots use so-called          opportunities that this market
                         u those with children;                “opportunity pricing.” In reality,    offers, even during the current
                         u consumers with annual               this means they base the price        economic slowdown.
                       household incomes of $25,000 to         of the car on what the buyer            This report will go beyond
                       $50,000;                                can afford. Each buyer is first         temporary factors and present
                       8
                         GDNAuto is an online marketplace
                                                               asked how much he or she can          ongoing strategic reasons why
                       that enables dealers and lenders to     raise from friends and family         credit unions should serve the
                       package car loans so they can be sold   for a down payment. The down          non-prime market to ensure
                       as asset-backed securities.             payment amount usually covers         long-term viability.


              6        Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  Lessons Learned

  The surveys and interviews           In 2007, James Nastars, Senior       resolution of failing loans.
conducted through this project       Vice President of Lending                The UFCU analysis revealed
reveal many examples where           at University Federal Credit           that just under half of sub-prime
credit unions have developed         Union (UFCU) in Austin, Texas,         applications are approved or
innovative loan products and         presented a research paper 9           “conditioned” for the borrower.
features to meet the needs           on his credit union’s two-year           However, only about half of
of non-prime used auto loan          experience with a pure risk-           approvals are actually funded.
applicants without sacrificing        based lending auto program that        Those that go unfunded do
financial safety and soundness.       features:                              so because the borrower can’t
  The information derived from         u loans priced according to          meet or is dissatisfied with the
credit unions and from suppliers     credit risk for those with credit      loan terms, or he/she obtains
that have developed products/        scores as low as 420;                  financing at the dealership.
services to meet the needs of          u encouraging members to               Applications that were not
this market are summarized           come to the credit union to get a      approved initially were typically
according to seven lessons that      loan approved before they go to        denied for at least one of four
contribute to a successful non-      an auto dealer;                        primary reasons:
prime auto lending program.            u loans underwritten to                u excessive debt in relation to
                                     mitigate the lender’s credit and       income;
                                     collateral risk;                         u lack of down payment,
LESSON 1: Non-prime used               u a full understanding by the        resulting in excessive loan-to-
auto lending is a financially         borrower of the loan terms and         collateral value ratios;
viable line of business.             his/her obligations under the loan       u previous negative car credit;
                                     agreement;                               u lack of a previous relationship
  Credit unions frequently             u a collections process that         with UFCU.
approach emerging markets            includes quick identification and         These reasons reinforce UFCU’s
with charity on their minds.                                                sound underwriting criteria.
This approach is limiting and        9                                        Due to the higher rates
counterproductive. There               James Nastars, “Analysis of Sub-
                                     Prime Lending Program, University
                                                             ”              determined by risk-based lending
are most certainly financial          Federal Credit Union                   (as depicted in Figure 4A), UFCU
opportunities in non-prime auto
lending. After all, sub-prime
                                        FIGURE 4A
financial service providers charge
unseemly rates and accumulate         Spread Analysis for UFCU’s Sub-Prime Auto
over-the-top profits. When
credit unions adopt a charity
                                      Loan Program
perspective, they have only a
fractional percentage of their                                            A+ paper             E paper
assets to engage. When credit          Loan Interest Rate*                 6.00%                17.00%
unions build a viable business
model, they have their full asset      Cost of Funds                       2.25%                2.25%
base to lend.                          Originating Costs                   0.72%                1.32%
Risk-Based Lending                     Servicing Cost                      0.32%                0.72%
  One existing credit union            Loan Losses                         0.03%                4.79%
practice that can be used for
reaching consumers with                Net Spread                          2.68%               7.92%**
lower credit scores is risk-
                                      *Assumes a 60-month term
based lending—where the loan
                                      Note: This example uses the interest-rate environment in place as of
rate charged depends on the
                                      12/31/06. At the time UFCU was charging 17% on E-paper loans, sub-
borrower’s credit rating in order
                                      prime lenders were charging 25% or more. Borrowers were still receiving
to match the anticipated risk with
                                      a much better deal at the credit union.
an appropriate interest rate.


                                     Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders       7
    netted more income on loans to         future loan losses.                   3% to 4% level. [It is] more than
    low-score borrowers (“E-paper”)          With sufficient experience,           adequate to make this part of our
    than to high-score borrowers           credit unions will be able to         portfolio productive. ”
    (“A+ paper). According to              adjust rate premiums to reflect          u “We have been able to save
    Nastars:                               their loan loss rates.                the members money when they
      “…the spread increases in the                                              initially had the loan financed
    lower credit tiers in order to         Risk-Based Lending                    elsewhere and we can refinance
    provide a reserve against future       Success Factors                       that auto loan with the credit
    losses. In economic downturns, it        When asked about the success        union. We normally can beat
    is likely that sub-prime loans will    of their non-prime auto lending                                         ”
                                                                                 their rate by several basis points.
    go bad at faster rates than prime      programs, some credit union             u “We find that many times the
    loans, as these borrowers do not       executives took the opportunity       A paper quality borrower is slow
    usually have a secondary source        to point out that these loans         to pay more than the D or E paper
    of repayment. Higher margins are       can be priced to cover risk           borrower, which is surprising.
    needed to fund reserves against        and still offer a better deal for      Members are so thrilled that
    such events. ”                         members. Others indicated that        the credit union gave them an
      ** It should also be noted that      delinquencies and charge-offs are      opportunity to borrow—they work
    this analysis took place during        acceptable and manageable. Here       hard at keeping their payments
    a period of strong economic            are their comments:                   current. ”
    growth. These E-paper loans              u “Our portfolio yield is more        u “We have been able to provide
    were made before the sub-              than 120 basis points above our       members financing with rates that
    prime mortgage crisis and              peers, and more than makes up         are considerably lower than they
    the unprecedented rise in gas          for our (above-)average charge-       would receive from other finance
    prices. As Nasters predicted, net      offs. It is a business strategy that   companies.  ”
    spreads on E-paper loans during        both fulfills our social mission and     u “We have had record years of
    economic downturns are typically       has a positive financial impact to     auto loan growth in this market
    much lower than the spread that        the credit union.”                    and have learned some things
    UFCU netted in 2006.                     u “We find that low-income           along the way to improve it.  ”
      Figure 4B illustrates what would     members have a great sense of           u “We have seen some losses
    happen if loan losses were to          pride when they commit to these       higher than peer on our portfolio,
    double on UFCU’s E-paper loans:        loans. Our delinquency rate is        but generally the interest rate
    Net spreads would nearly even out      less than 1%. ”                       earnings offset the losses.”
    with “A+” loans. This explains the       u “It has been successful with        u “…we’ve been able to serve
    need to charge relatively higher       delinquency and charge-offs better     these lower score applicants at
    interest rates on E-paper loans in     than industry [standards].  ”         reasonable rates as compared to
    order to build reserves to cover         u “Loss ratios continue at the      their other alternatives, all while
                                                                                 keeping delinquencies/charge-offs
                                                                                 in check. ”
       FIGURE 4B
                                                                                   Given the pervasiveness
     If E-paper Loan Losses Double                                               of predatory lenders in this
                                                                                 marketplace, credit unions
                                      A+ paper               E paper             are able to price these non-
                                                                                 prime loans for risk and effort
       Loan Interest Rate*                6.00%              17.00%              and provide members a better
       Cost of Funds                      2.25%              2.25%               deal. Even during the strongest
       Originating Costs                  0.72%               1.32%              economies and lowest interest
                                                                                 rate environments, car-buyers
       Servicing Cost                     0.32%               0.72%              captured by predatory lenders
       Loan Losses                        0.03%               9.58%              will typically pay at least 7
                                                                                 percentage points more than the
       Net Spread                         2.68%              3.13%**             federal credit unions’ statutory
                                                                                 interest rate cap of 18%.


8   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  Credit unions, as member-            underwriting criteria (other than                  the ‘whole picture’ when making a
owned cooperatives, have a vested      credit score) are:                                 credit decision.”
interest in helping members                                                                 u “…over the years, we have
become better credit risks.              u a good relationship and                        built a reputation—both through
                                       history with the credit union,                     the membership and our indirect
Price + Lender with the                  u a good payment history on                      dealers—that we will not
borrower’s best interest in mind       auto loans,                                        discount any application solely
= Better Deal                            u stable employment and                          due to their credit score. We will
  The comments of one NCUF             residence,                                         always consider ‘character’ and
Auto Loan Survey respondent              u and payroll or other                           circumstances before making an
concisely summarized the               automatic payment.                                 underwriting decision.  ”
assertion that non-prime auto            (See Figure 5.)                                    u “We underwrite based on
lending does not have to be                                                               judgment, then price the loan
considered charity work:               Character Lending Success Factors                  based on the risk it presents. ”
  “Don’t focus on just losses. Price     The link between character                         u “The key is to evaluate each
for the risk taken, and the overall    lending and successful non-prime                   individual on their own merit.   ”
profitability will be there even if     auto loan programs is illustrated                    u “We look at each applicant’s
losses are high.”                      by the following comments                          qualifications, no matter what
                                       from NCUF Auto Loan Survey                         their credit score, and try to
                                                                                          find a way to make the loan
LESSON 2: Reduce the                   respondents:
                                                                                          and educate the member when
                                         u “We do not make loans based
underwriting gap by                                                                       appropriate. The credit score is
                                       on credit score alone. We look at
transferring traditional
character lending                         FIGURE 5
techniques into an
automated decision-making                Underwriting Criteria for Non-Prime Auto Borrowers
process.
  Prior to 1995 and the advent                            Good payment history with the CU
of credit scoring, credit                               Good payment history on auto loans
unions used a form of loyalty
relationship lending they called
                                                                          Strong employment
“character” lending. Credit                              Payroll or other automatic payment
unions historically maintained                                      Credit scores below 620
better than industry charge-off
levels through a homogenous              Lower credit scores require a higher down payment
field of membership: knowing                                      Higher equity ratio required
members, knowing employers                                               Low unsecured debt
and workplace policies, and
using co-signers. Credit unions                            Offer share secured loan instead
do recognize the value of their                Advance money down in CU savings account
own data and relationships with                          Length of membership requirement
members. Old fashioned, high-
touch character underwriting                                         No credit score required
is effective for non-traditional                                                  Lend on ITIN
borrowers.
                                                           Internally generated credit score
  Character lending allows credit
unions to build an underwriting                                                         Other
basis that goes beyond the                                                                   0%    20      40      60      80       100%
credit score. At credit unions
that responded to NCUF’s Auto             Source: National Credit Union Foundation (NCUF) Auto Loan Survey, March 2008
Loan Survey, the most important


                                       Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders                   9
     a tool used primarily for pricing,    survey respondents apply these          When Income Drives Credit
     not decision-making.  ”               techniques to low credit score          Scores
       This lending process is similar     borrowers.
                                                                                     Corey Stone, CEO of Payment
     to situation-specific financial           There is no doubt that credit
                                                                                   Reporting Builds Credit (PRBC),
     education, where the loan officer       scoring is a quick, useful and
                                                                                   presents two situations that
     serves as a consumer advisor          consistent tool to assess the risk
                                                                                   suggest income could drive credit
     to the member. The member is          of loan applicants. Introduced
                                                                                   scores—even for consumers with
     educated on credit scores, debt       in 1995, credit scoring quickly
                                                                                   identical repayment performance
     ratios, auto buying and how           became prevalent among
                                                                                   on loans:
     to maintain a strong, positive        lenders due to many attractive
                                                                                     1. The percentage of available
     relationship with the credit          features: It’s fast, uniform, and
                                                                                   revolving credit line utilization
     union. Using this approach,           inexpensive; simplifies pricing;
                                                                                   is an important factor in credit
     credit unions try to thoroughly       encourages competition, and is
                                                                                   scores. A lower utilization makes
     understand why the credit score       not subjective or discriminatory.
                                                                                   for higher scores because it
     was low, pay attention to positive      However, there is evidence that
                                                                                   means you can tap lines to make
     or negative movement in the           credit scores can be affected in
                                                                                   payments in the short term.
     score, and evaluate what plans the    part by the borrowers’ income,
                                                                                   Income is an important factor
     member makes to improve their         not just their likelihood of
                                                                                   that lenders use in extending
     situation. This hand-holding also     repayment.
                                                                                   and augmenting credit lines,
     acts as a risk mitigation measure.
                                                                                   so a consumer with higher
       This approach can be extended
                                                                                   income is more likely to have
     from going over the credit report
     with borrowers, to building a
     budget, to car-buying workshops,       Alternative Credit Bureau Profile
     to assisting the members in
     reviewing the paperwork from a         Payment Reporting Builds Credit (PRBC) www.prbc.com
     dealer.
       Bad marks on the credit report          Thin-file consumers—those              Fair Isaac recently announced
     are treated seriously. Tax liens       with little or no credit history—      a collaboration with PRBC
     and medical debt must be in            make up an estimated 35                to collect, verify, and score
     repayment. Some credit unions          million to 50 million adults in        rental and bill payment data
     track the borrower’s credit score      the U.S. This represents about         with consumers’ approval.
     twice a year. Weak records             20% of the adult population.           The collaboration combines
     trigger the need for higher loan-      Youth, immigrants and                  PRBC’s verified data with
     to-value ratios or a co-maker.         emerging markets typically fall        FICO® Expansion® Score
       There are drawbacks to               into this “thin-file” category.         data and analytics. The
     character lending: long                   Payment Reporting Builds            companies promise to deliver
     processing time, and a need for        Credit (PRBC) is a service             a more complete and accurate
     specially trained and experienced      designed to enable lenders to          assessment of applicant
     loan officers. This is another           better evaluate these thin-file         risk—one that meets Fannie
     reason why loan rates need to be       applicants who have little or no       Mae, Freddie Mac, and HUD
     higher to cover costs of lending to    recent credit history. PRBC            requirements. Their goals are
     non-prime borrowers.                   acts as an “alternative credit         to address several problems
       Since character lending is           bureau” that tracks rent and           for lenders, and help qualify
     based on close relationships           other payments such as utilities,      creditworthy customers among
     (as with “friends, neighbors,          phone, cable, and wireless that        the large no-hit/thin-file group.
     and co-workers”), it has not           are not considered by the main           The combination of a FICO
     been practical to expand to            credit bureaus. This alternative       Expansion Score with PRBC
     new markets. While over                allows potential borrowers with        bill payment data could help
     80% of credit union survey             little or no credit history to build   uncover signs of risk that would
     respondents use expanded loans         a credit file.                          otherwise go unnoticed.
     processing, less than half of the


10   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
                                       Underbanked, Not Unbankable

                                                   Thin File/No File-50M
                                                (Traditionally non-scorable)         Subrime-47.7M
                                                                               (Scorable and Non-Scorable)

higher available lines and lower
utilization rates. (This is true
on a percentage basis, if not in                Thin File/No File—      TF/NN—            Subprime
absolute dollars).                             prime + near prime:      subprime:       (Traditionally
                                                      37.5M              12.5M            scorable)
  2. The number of trade lines                                                             35.2M
is an important factor in credit
scores—the more the better, up
to a point. In general, higher
income people are more likely
to receive unsolicited offers of
credit. In turn, higher income
people can support more active          A recent paper from the Center         scores offer the potential to
trade lines. For example, a           for Financial Services Innovation        reliably measure the credit
person who has enough income          suggests that alternative credit         risk represented by far more
to support a car loan plus three
active credit card accounts will       Alternative Lending Solution Profile
probably have a higher score than
someone who can only support           Forum Credit Union / Capital Lending Strategies, LLC
a car loan and one active credit
card account even though they          Assets: $1.06 Billion                   origination system featuring
have the same overall utilization      Members: 103,789                        scalability, confidentiality, on-
rates.                                 Location: Indianapolis, IN              line decisioning, and 24/7/365
                                       Contact: Steve Mundell                  user-friendly accessibility,
Automating Character Traits            Website: www.forumcu.com                backed by a leading insurance
                                                                               provider.
  The trick for credit unions in
                                         Forum Credit Union has                   Capital Lending Strategies
non-prime auto lending will be to
                                       developed a non-prime auto              (CLS) claims to be “one of the
automate the use of its traditional
                                       lending partnership with Capital        few companies in the country”
underwriting process—character
                                       Lending Strategies, LLC, of             that can provide Collateral
traits included—to supplement
                                       Irving, Texas.                          Value Indemnity coverage on
credit scores, or to evaluate and
                                         The credit union is leveraging        a loan-by-loan basis.” CLS
subscribe to bureaus that gather
                                       Capital Lending Strategies’             says this benefits both lenders
a wider spectrum of consumer
                                       Alternative Lending Solution            and borrowers. Lenders have
data.
                                       (ALS). This product intends to          an opportunity to protect their
  Several credit bureaus and
                                       increase an institution’s return        assets while providing auto
scoring agencies are trying to
                                       on assets (ROA) by creating             loans to borrowers that fall
offer scores to assess credit risk
                                       incremental direct and indirect         outside of their existing prime
among people with “thin files.”
                                       auto lending opportunities.             lending guidelines. Borrowers
Among the products available:
                                       ALS combines the platform of            with less than prime credit
  u eBureau from Experian;
                                       its Internet-based, automated           ratings can finance their auto
  u FICO Expansion Score from
                                       loan decisioning system with            purchases through financial
Fair Isaac;
                                       the benefits of a carrier rated          institutions.
  u L2C from TransUnion;
                                       “A” (excellent) by the A.M. Best           CLS concludes that lenders
  u Market Max from Equifax;
                                       rating agency.                          like Forum Credit Union could
  u RiskWise from LexisNexis.
                                         The carrier’s Collateral Value        “readily capture 30% to 60%
  This is good news. All of these
                                       Insurance product claims                of their current turn-down
products are intended to devour
                                       to substantially protect the            business,” while reducing
as wide a range of data as possible
                                       lender against financial losses          required loan loss reserves and
to make up for missing bureau
                                       resulting from repossession.            increasing ROA.
data. This includes receipts from
                                       The result, according to Capital           ALS is available with virtually
rent, layaway payments, utilities,
                                       Lending Strategies, is an               no “upfront” costs.
and online bill payment data.



                                      Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders        11
                                                                              purchasing, so that members
      Second Look Loan Program Profile                                         can negotiate intelligently and
      Capital Lending Strategies, LLC                                         confidently.
      www.clstrategies.com                                                      Credit unions will sell repos
                                                                              and returns of leasing from their
         As reviewed in Forum Credit      is funded by the credit union.      parking lots. As depicted in
      Union’s Forum Solutions             CLS purchases CUNA Mutual           Figure 6, several credit unions
      Blueprint: Subprime Auto            Group’s Lenders Protection          have relationships with local
      Lending, Capital Lending            (profiled in this report under       dealers to provide promotions
      Strategies (CLS) provides           Lesson 6).                          and referrals in exchange for
      software that takes a second          The dealer prepares a             a fixed mark-up for members.
      look at loans that are declined     package (proof of income,           More ambitiously, a few sponsor
      by the credit union as prime        mileage of car) and sends it        credit union owned dealerships.
      loans. The average FICO             to CLS to confirm terms. The           Car buying services
      approved by this method is into     credit union services the loan.     through Credit Union Service
      the 600s, but loan decisions          Of the loans initially rejected   Organizations (CUSOs) are a
      are made for FICO scores of as      by the credit union, CLS is able    fast growing option. Here, credit
      low as 500.                         to approve about 50%. About         unions eliminate the middleman
         FICO analysis is done by         25% of those approvals are          by establishing a credit union
      Mercer RFI. Additional data         accepted and closed by the          owned CUSO to work together
      reviewed includes proof of          dealer and the borrower.            to identify quality used cars with
      income and proof of residency.        Competing loan-decisioning        pre-arranged pricing. Existing
      There are eight credit tiers in     systems include FIData, Appro,      programs include, but are not
      the matrix built by CLS, with       SWBC, CRI and Agon.                 limited to:
      categories including debt-to-         Car dealers are also building       u Credit Union Direct Lending
      income and loan-to-value.           systems to bring this type          (CUDL) (www.cudl.com)
         The process flows from            of finance back under their            u CU Fleet (marketed under the
      the dealer, who sends an            control. (See www.dealertrack.      Central State Mortgage (CSMC)
      application to the credit union.    com.)                               umbrella of CUSOs) (www.
      The credit union gets the             Typically, credit unions expect   cufleet.com)
      application. If declined, the       acquisition fees of $700 to           u United Buying Service (www.
      full file automatically passes to    $1,200 from dealers. As the         ubs4cars.com)
      CLS staff at the credit union.      risk increases, the net yield is      Motor Vehicle Certification
      If CLS approves the loan, it        higher.                             Program (www.mvcp.com/intro.
                                                                              php)
     individuals than can be assessed     finding cars. This can begin as an     u Cars for Members (www.
     with traditional data.               extension of financial counseling.   carsale.com)
       Credit unions have used non-       According to one NCUF Auto            u Auto Resource Center (www.
     traditional credit criteria in the   Loan Survey respondent, “We do      cucompanies.net/pages/auto_
     past, and continue to do so. But,    review purchase agreements and      about_us.asp)
     these systems are not compatible     will help negotiate sales price,      u Autoland (www.autoland.
     with the time frames required to     especially with dealers that have   com)
     be competitive, especially with      excessive markups which impact        Another NCUF Auto Loan
     indirect lending.                    loan-to-value.”                     Survey respondent wrote,
                                            Passive approaches include        “We recently partnered with
                                          offering a Carquotes website         Enterprise and introduced a
     LESSON 3: Get in front               (www.carquotes.com or www.          program called SmartBuys. The
     of dealers by assisting              pricehub.com). Credit unions        program is specifically targeted
     members in finding cars.              may assist members with online      to low- and middle-income
      One way to recapture or             price assessment of the cars they   members to assist them with
     maintain direct contact with         are trading and the cars they are   locating a reliable and economical
     members is to assist them in                                             car.”


12   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
Indirect Lending            FIGURE 6                                                  loans account for
                                                                                      80% of net auto loan
  Indirect lending
generates an almost      Types of Assistence Offered                                  growth.
                         to Help Members Find a Car                                     Indirect lending
religious passion
                                                                                      does not get in front
among credit unions
                                                                                      of dealers – but it does
on both sides of the       Agreement with local dealer                                put credit unions in a
issue. Some believe
                                                                                      position to get in front
that credit unions have               Online car buying                               of borrowers they
to do indirect lending
                                                                                      otherwise would not
to make enough loans
to survive. Others
                         Car sale through rental agency                               have an opportunity
                                                                                      to reach with auto
believe that letting
someone come                    CU owns a used car lot                                loans. Indirect
                                                                                      lending dealerships
between the credit
union and the member              CU owns a dealership                                in effect become
                                                                                      mini-branches, which
is contrary to credit
unions’ mission.                                       0% 10 20 30 40 50 60%          increases the credit
                                                                                      union sales force.
  One point is
                         Source: National Credit Union Foundation (NCUF)                However, when new
undeniable: Indirect
                         Auto Loan Survey, March 2008                                 members go to dealers
lending accounts
                                                                                      first, the credit union
for 40% of credit
                                                                                      is a nearly invisible
unions’ auto lending.
                                                                                   wholesale lender.
According to CUNA                     credit unions participate in
                                                                         Converting indirect borrowers to
Mutual Group, about 63% of            indirect lending programs. These
                                                                         full service members is not easy.

  Credit Union Finance Company Profile
 SELCO Community Credit Union
 Assets: $784 Million                Lending Outlet has attracted         34% of SELCO’s regular
 Members: 77,324                     a new type of member for             membership.
 Location: Eugene, OR                SELCO. About one-third of            u 39% have a share and loan
 Contact: Douglas Grout              the loans derived from this          only.
 Website: www.selco.org              company are in the D and E           u 43% have a checking
                                     category. Interestingly, the         account.
   In June 2006, SELCO               business has also attracted          u 71% are homeowners.
 Community Credit Union              about $1.5 million in platinum       u Average deposit balance:
 established a separate finance       paper—borrowers with good            $853
 company called The Lending          credit but who may not have          u Average loan balance:
 Outlet to expand the credit         a trusting relationship with         $12,625 (10.95% weighted
 union’s target market and steer     mainstream financial institutions.    average rate)
 borrowers away from predatory                                            u 2007 loan production: $7.5
 lenders and predatory loans.          The Lending Outlet                 million in loans; 627 new
 Although The Lending Outlet         (finance company of SELCO             members; $54,110 in loan
 looks like a finance company         Community Credit Union)              losses
 location and has a different        u 728 members                        u Average number of accounts
 feel from the credit union, the     u 48% of members generated           per member: 2.77
 business offers the same rates      from The Lending Outlet have         u Average annual net income
 as the credit union.                household incomes below              per member: $170
   The look and feel of The          $40,000. This compares to



                                     Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders      13
      CUSO Profile
     Credit Union Direct Lending (CUDL) www.cudl.com
       Credit Union Direct Lending       simplifying the buying process       vehicle is lost or stolen, CUDL
     (CUDL) was established to           and getting members the best         GAP ensures that both the
     provide point-of-purchase           price when they buy a vehicle.       member’s investment and the
     lending for the credit union        The AutoSMART program                credit union’s investment are
     community. CUDL has grown           also allows for co-branding          protected.
     to become the nation’s largest      opportunities.                         CUDL Financial Services
     point-of-sale and indirect            Other CUDL services include        is a sub-prime program to
     lending network owned by            back office indirect lending,         auto dealerships, accessible
     credit unions. Today, the           web-based ASP solutions,             through the CUDL platform.
     CUDL network of credit unions       and insurance for lost or stolen     Members and non-members
     and dealers serves nearly 18        vehicles.                            who do not qualify for credit
     million credit union members          CUDL GAP™ offers a                 union financing may qualify for
     nationwide.                         guaranteed auto protection           CUDL Financial Services. This
       CUDL’s most popular               product, which can be made           program promotes competitive
     product is the AutoSMART            available to credit union            financing with the same speed
     program, a web-based interface      members at the auto dealership       and convenience of the CUDL
     designed to increase credit         or directly at their credit          system.
     union member satisfaction by        union. When a member’s

      Rental Car Sales Program Profile
     Schools First Federal Credit Union/
     Enterprise Car Sales
     Assets: $7.5 Billion                credit union has dedicated one       days, Enterprise guarantees car
     Members: 376,789                    team member to “keeping the          buyers’ continued satisfaction
     Location: Santa Ana, CA             hype,” stocking brochures, and       by including a 12-month /
     Contact: Shelly Berryman            communicating the story.             12,000-mile limited power
     Website: www.schoolsfirstfcu.          The SmartBuys program              train warranty and one year of
                org                      allows the credit union to keep      roadside assistance.
                                         three vehicles on the property—
     SmartBuys                           priced $1,000 to $1,500 below        TRIP—Timely Repayment
       Partnerships are another way      Kelley Blue Book value. (For         Incentive Program
     for credit unions to expand their   example, a recent selection of         Another innovation for
     offerings to members. Case in       cars included a 2007 Chevy           non-prime borrowers is a
     point: the “SmartBuys” program      Cobalt at $9,999, a 2007             program called TRIP (Timely
     that Schools First Federal          Chrysler Sebring at $13,999,         Repayment Incentive Program).
     Credit Union has developed          and a 2007 Dodge Grand               TRIP allows all non-prime
     in partnership with Enterprise      Caravan at $15,499.)                 borrowers to improve the rate
     Car Sales. In a six-month pilot       The program is specifically         on their loan by .5% after 12
     at one branch, the SmartBuys        targeted at low- and middle-         on-time payments. This is
     program provided 12 members         income members to assist             an opportunity for borrowers
     with access to “low cost,           them with locating reliable and      to automatically adjust their
     reliable vehicles.”                 economical cars. Enterprise          loan to the best rate that was
       Based on its success,             works to ensure the quality of       available at the time their loan
     Schools First Federal Credit        each car by first conducting          was originated (assuming a
     Union (formerly Orange County       a 109-point inspection by an         maximum risk up-charge of 50
     Teachers FCU) is planning           ASE-certified technician. Each        basis points at origination). The
     to roll out the program in two      vehicle comes with a seven-          earned interest rate reduction
     additional branches this year.      day repurchase agreement             allows a greater percentage of
     In this partnership, Enterprise     so that it can be returned for       each payment to go toward the
     will provide brochures and          any reason—no questions              principal.
     marketing materials, while the      asked. After the first seven



14   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 Credit Union Partner Profile                                             Regional Differences
                                                                          There is an astounding
 Enterprise Car Sales www.cuautodeals.com/                              variation in regional auto
 www.enterprisecarsales.com                                             markets, based on the amount
   Enterprise Car Sales has         for members to view.                of market share credit unions
 partnered with credit unions         Enterprise offers haggle-free     control. Where credit unions
 for decades, providing used        pricing and sells 120 makes         are bit players, credit unions pay
 vehicles and guaranteeing          and models of vehicles priced       dealers for referrals. In areas
 that credit unions will get the    below Kelley Blue Book value.       where credit unions dominate the
 financing. Today, Enterprise        Vehicles from Enterprise are        market, dealers pay credit unions
 works with more than 1,000         typically one to three years        a loan loss reserve. (One credit
 credit unions across the U.S.      old. Each vehicle undergoes         union calls this their “acquisition
 to develop a successful plan       a 109-point inspection before       fee: $495 from dealers to reserve
 to help drive credit union auto    being listed as one of nearly       for loan losses”).
 loan volume.                       8,000 cars available for sale         It’s as if in some areas a
   Partnerships with Enterprise     online and in 178 car sale          customer pays for goods at Wal-
 are developed on a case-by-        branches throughout the             Mart and, and in another area,
 case basis. They usually focus     country. Each vehicle comes         Wal-Mart pays the customer
 on marketing strategies that       with a limited power train          to take the goods. Similarly, in
 range from providing basic         warranty, roadside assistance,      some regions, an 80% loan-to-
 marketing brochures to larger      and a seven-day repurchase          value (LTV) ratio is standard,
 promotional events where           agreement.                          while in others, credit unions are
 Enterprise places cars on-site                                         not getting loans unless they go
                                                                        to 125% LTV.
                                                                          Is indirect lending worth the
  Many credit unions accept         fraud exposure. However, credit     price? Credit unions have found
indirect borrowers as single        unions usually do not have a        success on both sides of this line
service members.                    commercial loan relationship        in the sand.
  Remar Sutton, with the passion    with the dealer.
of a converted car dealer, opined
that credit unions will never        Saver’s Loan Program Profile
be able to capture the ethical
side of this financing market in      Fitchburg ME Federal Credit Union
partnership with dealers. CUNA
Mutual Group figures show that        Assets: $25 Million                10% of the loan payment into
credit union members are 37%         Members: 3,174                     a dividend-bearing account,
more likely to repay than those      Location: Fitchburg, MA            which is secured until the loan
who become members via the           Contact: Barbara Goodwin           is paid. The loan is pledged
indirect route.                      Website: www.                      into the savings account and
  Indirect lending necessitates      fitchburgmefcu.com                  the savings earns dividends at
quick decisions and funding—10                                          a low rate (e.g., 0.5%).
minute turnaround. It thereby          Fitchburg ME Federal Credit        Loans are for a 10-year
increases reliance on fully          Union has developed a savings      maximum term with a 90%
automated lending.                   program for low credit score       loan-to-value ratio. Usually a
  The longstanding bank model        borrowers or borrowers who         five-year loan will be paid back
for indirect lending was to          can’t get a co-signer. This        in four or 4-1/2 years.
underwrite the dealership            includes young people without        Fitchburg ME FCU also
through a floor plan commercial       credit.                            participates in the Enterprise
loan. The commercial banking           In most cases, the vehicle       Car Sales program profiled
relationship with the dealer         purchased is a used car.           under Lesson 3 in this report.
provided some recourse and             The savings program allocates
discipline to lessen indirect

                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders    15
     LESSON 4: Employ a “hard                  collected, including a picture of         financially and for the future….
     close” to cement bonds                    the vehicle.                              We commit that if they pay
                                                 This documentation and                  us, they can depend on future
     with members.
                                               education process provides                auto loans as long as we can see
       About half of responding credit
                                               a solid defense against the               positive financial management
     unions found a “hard close” to be
                                               increased delinquency that comes          efforts. They see us as a partner in
     an effective way to improve loan
                                               with moving down the credit               their financial success. ”
     repayment performance. Since
                                               score scale.                                u “Close the loan hard at time
     dealers come between members
                                                                                         of closing. Also we tell member[s]
     and the credit union during the
     sales process, a hard close allows
                                                    “Hard Close” Success Factors         that building credit with us will
                                                       Several NCUF Auto Loan            help them for future needs.”
     the credit union to cement bonds
     with members and get them                      Survey respondents mentioned
     started on the right foot.                     the significance of hard-closing
       To employ a hard close: When                 the loan as a key to the success of LESSON 5: Insure borrowers
     members are ready to sign for a                their program:                          against events out of the
     loan, take some extra time to:                    u “A strong loan closing is very     realm of their control.
       u Thank them for their                       important.  ”                              Ninety percent of credit union
     business;                                         u “A need to gain a firm              respondents to the NCUF Auto
       u Verify information in their                commitment from the borrower            Loan Survey offer member-paid
     loan application;                              at closing (i.e., the hard close) [is a insurance coverage(s).
       u Review and confirm that the                 lesson we learned].   ”                    Credit disability and credit
     members understand loan terms                     u “We always educate our             life are the protections most
     and consequences such as the                   members about credit scores and         commonly offered, followed
     monthly payment amount, date                   budgeting. Lesson: Closing the          by guaranteed asset protection
     due, insurance requirement, late               loan properly is a must.   ”            (GAP) loan deficiency or residual
     fee and penalties;                                u “The pre-close counseling          value insurance, and mechanical
       u Reinforce the value of                     includes awareness of what              breakdown insurance (MBI) or
     membership by explaining that                  the financing means to them              extended warranties. In addition,
     the credit                                                                                      some credit unions offer
     union is willing                                                                                debt cancellation products
     to assist if/         FIGURE 7                                                                  to cover events such as
     when there are                                                                                  divorce, injury, and/or loss
     problems so          Insurance Coverages for Non-Prime                                          of job. (See Figure 7.)
     the members          Auto Lending                                                                 These coverages
     should stay in                                                                                  particularly benefit lower-
     contact with the       Credit disability protection                                             income borrowers who are
     credit union;                                                                                   less likely to be covered
       u Cross-sell               Credit life protection                                             by other private insurance
     appropriate          Guaranteed asset protection                                                policies.
     products such
     as direct deposit         Mechanical breakdown                                                  Insurance Success
     and automatic
                                      Debt cancellation
                                                                                                     Factors
     payment.                                                                                          Some credit union
       Credit union                   Assure insurance                                               executives suggested that
     representatives                                                                                 one key to the success of
     witness the                              Walkaway
                                                                                                     their non-prime auto loan
     signature,                                        0%      20      40     60     80 100%         programs is borrower
     and detailed                                                                                    insurance:
     information           Source: National Credit Union Foundation (NCUF) Auto Loan
     about the             Survey, March 2008
     collateral is



16   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
                                        FIGURE 8
                                        Primary Causes of Default Among Loan Financing
                                        Programs with a Loan Component

                                                       Lost job
                                         Cannot pay for repairs
                                        Cannot make ends meet
  u “Get them to take mechanical
breakdown insurance because                         Car failure
they cannot afford the repairs
later.
     ”
                                                    Relocation
  u “GAP insurance is a definite
[to have] these days. ”
                                                      Accident
  u “We push for … acceptance
                                               Injury or illness
of disability, GAP and life
insurance.…  ”                                                 0%   10   20      30     40     50     60      70   80%
  u “We also implemented [the]
same loan payment with or               Source: National Credit Union Foundation (NCUF) Auto Loan Survey, March 2008
without insurance. We simply
extend the term of the loan
to cover the cost of insurance
                                      Concept in Motion
protection. So far, members don’t
mind the extra payments as long       Walkaway Protection www.walkawayprotection.com
as the payment fits their monthly
cash flow/budgets.  ”                    U.S. credit unions now have           u loss of driver’s license due to
  According to a recent survey        access to programs that                 medical impairment;
of low-income car ownership           allow drivers to walk away              u self-employed personal
programs, the most prevalent          from their lease or loan when           bankruptcy;
causes for non-prime borrower         certain circumstances occur.            u international employment
defaults are losing a job, budget     One such package is offered             transfer.
constraints, and car failure. (See    by Walkaway, a Canadian                   An elite Walkaway program
Figure 8.)                            company that now serves U.S.            provides more protection by
  All of the write-offs identified      credit unions.                          covering:
in Figure 8 (except for the third       A standard Walkaway                   u temporary lay-off from a full-
related to budget constraints) are    program covers:                         time, non-seasonal job;
losses that could be insured with     u involuntary unemployment;             u mental health disability;
the aforementioned products.          u physical disability;                  u accidental death.
  Credit unions wishing to engage
in this higher-risk profile market     Credit Union Insurance Profile
can build a combined package
of insurances that make the net       Tropical Financial Credit Union
income of these non-prime auto        Assets: $721 Million                    disabled.
loans more predictable. These         Members: 66,136                           Each insurance policy adds
coverages primarily protect           Location: Miramar, FL                   approximately $20 to $30 to
the member, and secondarily           Contact: Jim Wagy                       the monthly payment of the
the credit union. Nonetheless,        Website: www.tropicalfcu.org            loan.
CUNA Mutual Group has found                                                     The optional insurance has
that the more insurance products        To protect against losses,            been widely used by TFCU’s
on the loan, the better the loan      Tropical Financial Credit Union         members since 1991. About
performs.                             (TFCU) offers two forms of              80% of TFCU’s auto loans
  There is an opportunity for         insurance—credit life and credit        include either credit life or
credit unions to provide a            disability—for the majority of          credit disability.
package of finance and insurance       the loans in its $220 million             The credit union has
that offers each borrower a car        portfolio. Underwritten by              found that credit-challenged
with the assurance that payments      Minnesota Life, the insurance           borrowers generally like the
are only required when the car        pays in full with no fees or            product, because they don’t
works and the member has a job.       additional costs if the borrower        usually have much insurance.
                                      passes away or becomes



                                     Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders        17
Preferred Dealer Profile
Coastal Federal Credit Union / CUDL
Assets: $1.8 Billion                    approximately 500 dealers in its          to build a connection with or loyalty
Members: 170,000                        operating area alone. Realizing that      to the credit union. To mitigate
Location: Raleigh, NC                   500 dealers may be overwhelming           losses, CFCU insured itself with
Contact: Peter VanGraafeiland           for members, and that the majority        Lenders Protection from CUNA
Website: www.coastalfcu.org             of CFCU’s loans come from a small         Mutual Group. (See the Lenders
                                        pool of dealers, the credit union         Protection Profile.)
  At Coastal Federal Credit Union       developed a “preferred dealer”              Lenders Protection charges a
(CFCU), four out of five auto loans      relationship with approximately 30        technology fee for the service (in
come through indirect channels.         dealers in the area.                      the range of 2% to 3% of the total
So developing solid partnerships          The preferred dealer arrangement        amount financed). However, CFCU
and offsetting risks from borrowers     allows the dealership to upload a         believes the fee is well worth the
who may never visit a credit union      flyer of deals and offers directly         offset in risk. CFCU originally used
office are high priorities.              onto CFCU’s website, building a           Lenders Protection for loans with
  In 2003, CFCU became the              closer relationship between the           a credit score of 640 and below.
first credit union in North Carolina     credit union, members, and the            But starting in February 2008,
to use the Credit Union Direct          dealership.                               the credit union decided to have
Lending (CUDL) programs profiled           Protection against loss is              Lenders Protection cover its entire
under Lesson 3 in this report.          especially critical for indirect loans,   portfolio.
  CFCU estimates that there are         as indirect borrowers are less likely



Lenders Protection Profile
Lenders Protection www.cunamutual.com
  Lenders Protection is a web-based     loan officer the appropriate deal          submitting a claim.)
technology from CUNA Mutual             structure, including the suggested          Lenders Protection also pays up
Group that delivers instant decisions   contract interest rate and loan term.     to 60 days interest to give the credit
and loan alternatives to members.       This contract interest rate enables       union time to repossess and sell the
  Lenders Protection offers             the credit union to recover the cost      vehicle.
72-month loan terms and 125%            of the program and build a reserve          The intent is for credit unions to
loan-to-value, plus rebate-able         to cover uninsured risks.                 manage and pool the risks of default
add-ons. Coverage applies both            The lender pays CUNA Mutual             on direct and indirect loans.
to current model year vehicles and      Group an upfront fee, which is              The insurance costs a credit
models up to seven years old.           recovered as the loan is repaid.          union between 2% and 22% of the
  To ensure that each borrower          Should the borrower pay off early, a      loan value, depending on the risk
receives a competitive interest rate,   partial premium refund is available.      evaluation.
the cost of insurance is calculated       In cases of default, Lenders              About 60% of premiums are paid
based on the risk each individual       Protection pays the difference            out to cover losses. The average
borrower presents—not on a blanket      between the loan balance and the          loss on a non-prime auto loan is
rate across all eligible loans.         greater of:                               $7,000.
  Loan decisions with Lenders             (a) 80% of the wholesale trade            Competitors in this market
Protection are made through             value of the vehicle at the time of       include Ameriquest, Capital One,
an Internet-based insurance             default, or                               and Triad at Ford Motor Company
decision system. If the applicant         (b) the amount for which the credit     (which approves FICO scores from
meets the insurance criteria, the       union has sold the repossessed car.       525-580).
system communicates back to the         (Repossession is a prerequisite for



     18   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
LESSON 6: Export risks by            insurances exist to reduce the
using available loan loss            credit union’s risk.
                                       A completely different approach
insurance products and
                                     is envisioned by the corporate
guarantees.                          credit union network with
  Different sets of coverages         Charlie Mac and its CARPooL
protect the credit union directly.   program. Such loan sale and
Default and collateral protection

 Non-Profit Profile
 Opportunity Cars www.opportunitycars.com
    Opportunity Cars is a network    insured depository account.            Opportunity Cars organizations
 of more than 150 non-profit          u If Opportunity Cars offers        offer an array of additional
 organizations dedicated to          tiers of service, a credit union    services to help ensure their
 increasing private automobile       could begin by financing the top     clients’ success. At the start
 ownership for low-wage              tiers and move down as it gains     of the relationship, they either
 working families to support their   experience and confidence.           directly deliver or make referrals
 ability to find and retain quality     Opportunity Cars organizations    to partner organizations that
 employment, and to improve          help approximately 10,000           deliver support services
 their overall well being.           low-income families with their      including financial counseling,
    Several credit unions have       transportation needs each year      assistance with insurance, and
 partnered with Opportunity Cars     by using one or more of the         car maintenance workshops.
 organizations to export risks       following approaches:                  Pre-qualifying could include
 and receive certain guarantees.     u Providing a car;                  requiring employment or a
 Potential partnership               u Providing a low cost loan;        commitment for employment,
 configurations are outlined here:    u Matching consumers’ savings       possession of a valid driver’s
 u Opportunity Cars can offer        for car purchases or down           license, or review of the driving
 a partial guarantee to a credit     payments.                           record. If a car buyer is receiving
 union in the event of a deficiency     When programs are providing       a car loan, the program may help
 after repossession.                 cars directly to families, some     ensure the borrower receives
 u Opportunity Cars could            of the cars are provided at no      an affordable and reliable car
 set a guaranteed earnings rate      or low cost. Others are sold        by arranging for the car to be
 for a mutual fund type pool         using a tiered pricing model        inspected, determining the fair
 of loans, based on its write-       and supported by technical          market value, checking the car
 off experience. (This means         assistance. About half of           history, or providing assistance
 Opportunity Cars would “profit”      Opportunity Cars programs have      with online auto shopping.
 if defaults were lower.)            financial institution partners.         After the sale, Opportunity
 u A credit union could provide        Each program is different.        Cars organizations may provide
 floor plan inventory finance as       Many rely on donated cars, but      other services including ongoing
 working capital (i.e., the credit   some programs purchase cars         repair and maintenance training,
 union underwrites Opportunity       from dealers, at auctions, or       a warranty or service agreement,
 Cars).                              through government fleets.           and in some cases, an escrow
 u A credit union could finance         Organizational funding comes      for repairs in the financing.
 fixed assets of Opportunity Cars.    from different sources including       The average Opportunity Cars
 u A credit union could set a        Job Access and Reverse              loan is $3,200 for a 24-month
 binding agreement to finance         Commute, Temporary Assistance       term with an 8% interest
 a second car upon timely            for Needy Families, Community       rate. The down payment is
 repayment of the Opportunity        Service Block Grants, the Office     accomplished through a $2,400
 Cars loan.                          of Refugee Resettlement, private    grant. The delinquency rate is
 u A savings component could         foundations, and revenues           7%.
 be added to the loan to build an    generated through car sales.


                                     Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders    19
                participation programs enable                   Across the board, credit            early collections, and
                credit unions to sell auto loans to           unions recognize the benefits of       creating/maintaining open
                a credit union-focused secondary              modifying the collection process      communications with non-prime
                market investor, while retaining              when originating non-prime            borrowers:
                the servicing.                                auto loans. Loans based on              u “[We utilize] continuous
                  Another approach is the                     lower credit scores will receive      monitoring of lower tier
                National Federation of                        attention more quickly when           delinquency performance and
                Community Development Credit                  collecting (e.g., on days 1 to 15)    open communication with our
                Union’s PRIDE program, which                  and repossessing (e.g., on days 30    collections group to ensure that
                will absorb 25% of the losses                 to 60). (See Figure 9.)               credit granting guidelines are
                when participating credit unions                                                    reflective of loss experiences. ”
                engage in aggressive outreach                  The practice of “proactive             u “[Our program] has been
                lending.                                      collection” is aggressive, but it’s   successful because we monitor it
                                                              not abusive.                          on a regular basis. ”
                LESSON 7: Keep in                                                                     u “We also feel that collection

                touch with borrowers by
                                                              Collections Success Factors           calls need to be done immediately
                                                                The following comments from         (within seven days from
                allocating resources to                                                             delinquent account) instead of
                                                              credit union executives help
                monitor and collect loans                                                           waiting to call them after 30 days
                                                              to illustrate the importance
                at the first sign of trouble.                  of continual monitoring,              past due. ”
                                                                                                      u “We always try to work WITH
FIGURE 9                                                                                            the member at all levels, and by
                                                                                                    keeping in touch, we have been
Risk Mitigation Techniques for Non-Prime Auto Lending                                               able to keep our delinquencies
                                                                                                    down. But the most important
                                                                                                    thing is to keep at it before it
                 Limit loan to Blue Book value                                                      becomes too big to work anything
                                                                                                    out.”
    Set max. loan duration based on age of car                                                        u “Good tracking and
                                                                                                    monitoring is the key to a
                Verify the information provided
                                                                                                    successful program.   ”
    Schedule payment when member gets paid                                                            u “You have to get in touch
                                                                                                    with [delinquent non-prime
  Require min. time at job/in field/at residence                                                     borrowers], sometimes at one day
                                                                                                    past due. ”
                       Five-day collection call                                                       u “We work with members for
                       Set portfolio loan limits                                                    payments when issues create late
                                                                                                    payment. Repossessions benefit
Make sure they carry member-elect insurances                                                        no one. Collections department
                                                                                                    personnel speak to them. We
          Proactive collateral recovery system                                                      tell them about the credit union
     Regularly analyze members' credit scores                                                       difference and that we are taking
                                                                                                    a chance on them that other
         Repossess the vehicle at 30 days late                                                      financial institutions would not
                                                                                                    take. ”
                     Forced savings for repairs                                                       u “Our institution offers a
                                               0%   10   20   30    40     50    60    70   80%     delinquent borrower a $25 pre-
                                                                                                    paid card for visiting the collector
                                                                                                    in person. The focus is on healing
Source: National Credit Union Foundation (NCUF) Auto Loan Survey, March 2008                        the breach and restoring member
                                                                                                    loyalty and good will.  ”



          20     Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
Effective Collections
u Billings Federal Credit Union
  - Look for ways to say “Yes”
  - 25% of portfolio is C&D borrowers (<620)

u Two Simple Collection Steps:
  - #1 Call delinquent accounts on Day 1;
  - #2 When accounts become delinquent, take action quickly!


Direct Lender Profile
Billings Federal Credit Union
Assets: $64 Million                 come up with a down payment.
Members: 8,034                      As a result, Billings FCU’s
Location: Billings, MT              riskiest loans have, on average,
Contact: Tom Boos                   an 80% loan-to-value ratio.
Website: www.billingsfcu.org          Limiting the loan-to-value
                                    ratio helps mitigate losses.
Lending Overview                    But losses do occur, and
u $23 million portfolio             they can cause discomfort for
u 2,471 auto loans on  the          credit union boards. An early
books                               strategy for engaging the board
u Focuses on direct loans           is to clearly communicate the
(88% of the portfolio)              reward for taking on additional
                                    risk. Although Billings FCU’s
  With 15% of car loans in the      charge-offs are higher than the
“D” category, Billings Federal      norm (0.6% in 2007), the net
Credit Union has figured out         yield – 110 basis points above
how to serve riskier borrowers      peer group average – more
through relationship building.      than makes up for these higher
  By focusing on the direct         charge-offs.
lending channel, relationship         If a loan defaults, dedicated
building and loyalty to the         and focused collections and
credit union’s mission begins       follow-up tactics are necessary.
in the initial interview process.   Billings FCU pays much more
The message for high-risk           attention to borrowers with low
borrowers at Billings FCU is        credit scores. This improves
that “we’re willing to help and     their ability to keep the loans
work with you, but this requires    current. For “C” and “D” paper,
a commitment.”                      the credit union’s collection
  Part of this commitment is        department will call on day one
financial. When pressed, the         of the delinquency, whereas it
credit union has found that         will let “A” and “B” borrowers
most people will be able to         slide for 15 days.




                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   21
       Other Observations

     Marketing Practices for              looks like a finance company            opportunity to meet the member
     Non-Prime Used Auto Loans            location, with a name different         with a counter-offer; a counter-
                                          from the credit union. This            offer can be developed for every
       Many of the successful ideas       concept has also been successful       situation. No matter what the
     revealed in the NCUF Auto Loan       in reaching non-members with           financial situation of the member,
     Survey are simple revisions in       payday lending and check-              there is a financial step in the
     the way products are presented       cashing services.                      positive direction right in front
     to members. The ideas reviewed          7. First Time Auto Loans            of them. Opportunities Credit
     in this section are generally        are loans to 16-year olds with         Union in Burlington, Vermont,
     product features and marketing       a parent/guardian co-signer …          uses a tag line, “We don’t say no,
     approaches, rather than full         or in another case, for military       we say ‘when.’” That statement
     lending products and processes.      members only.                          expresses their intent to turn loan
       Credit unions should consider         8. Second Car Loan is a clever      denials into opportunities for
     utilizing the following marketing    follow up. Recent reports from         both the credit union and non-
     approaches when designing and        the payday lending industry            prime members.
     promoting a non-prime auto loan      indicate that customers only stay
     program:
       1. Lower Interest Rates, and
                                          with them for two years because a      Accepting Market
                                          life event (e.g., new job, marriage,   Segmentation, Not
     interest rates tied to additional    relocation) moves them to a
     factors besides credit scores, are                                          Discrimination
                                          different set of services. Credit
     constant credit union themes.        unions, by engaging in the non-          Unfortunately, some credit
       2. “See Us First” is a popular     prime market, can assure that the      unions hesitate to promote
     attempt to get to members            next set of services is at a credit    non-prime vehicle loans to the
     before the finance and insurance      union by putting in place “step-up     distinct market segments that
     salesman does (at dealers without    products” to ensure a continuous       those loans are designed to serve.
     credit union partnerships). Sadly,   service pathway for migrating          For example, as one respondent
     even when members leave the          members.                               explained, “When [we] market,
     credit union with a car purchase        9. Saver’s Loan puts 10% of         we market to all our members.”
     check in hand, half of approved      each payment into a dividend-            Verbatim comments from credit
     borrowers are recaptured by a        bearing account, which is secured      union survey respondents reveal
     dealer.                              until the loan is paid. This can       that significant confusion exists
       3. Auto Recapture guarantees       be marketed as a repair reserve        between market segmentation
     that the credit union will           or a down payment for the next         and discrimination. Some credit
     refinance loans from other            car. Hybrid, linked, and bundled       unions believe that adherence to
     institutions to a lower interest     products build the cross-sell into     democratic principles means that
     rate, often without a credit         the product.                           they must treat all members the
     analysis, as long as members have       10. Marketing to Non-prime          same—with no special deals, and
     paid “as agreed” for some period     Borrowers is handled through           no targeted approaches.
     of time. Some credit unions pay      store branches, through dealer           To suggest a non-controversial
     members a $50 premium for            referrals, by staffing a desk at         counter-example, a credit union
     refinancing.                          the dealership, and of course, by      wouldn’t want to promote
       4. Timely Payment Reward           word of mouth referrals from           mortgage loans to middle school
     automatically lowers the interest    other members.                         students. When you want to hit
     rate when a member pays on-             11. Premium Promotions have         a target, you have to aim. When
     time for 12 to 24 months.            been successful. A free gas card       you want to reach a person, you
       5. Basic Transportation            and a free mechanical inspection       have to talk to them in ways
     Program is a bundle of services      are two examples.                      they find compelling. This
     (used car, small loan, insurance        12. Say “No” Better. The            discriminatory mindset must
     premium financed) for car             adverse action process itself does     change and evolve before a credit
     owners with modest means.            not do justice to the not-for-         union will be able to successfully
       6. Re-branding is an ambitious     profit cooperative credit union         serve untapped and underserved
     approach to build a branch that      mission. Each loan denial is an        consumers.


22   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  That said, it will take time for   research and market testing with     of NCUF Auto Loan Survey
some to change their institutional   innovative companies seeking to      respondents work with
culture. One survey respondent       successfully serve underserved       BALANCE, Accell, or a consumer
lamented, “As a traditional          markets. Weiser notes, “If we        credit counseling agency.
‘A-paper’ shop, we’ve found it       had to put everything we have
difficult to change the mindset        learned into a nutshell, we would    Potential Partnerships
of the loan decision-makers.”        say that the most important            Less than a third of survey
Attention has to be invested in      overarching                          respondents report more
justifying the focus on emerging     success                              substantial and far-reaching
markets and on training staff and     factor is to                         partnerships. The most obvious
the board on how to respond.         create value                         opportunity for partnerships
  Along with any opportunity         for the                                                is with non-
comes risk. In order to minimize     community                                              profit auto
the risk, successful credit          at the same                                            programs. The
unions adapt their products          time as                                                vendor profile
and practices to the market. In      you create                                             of Opportunity
addition, successful credit unions   value for                                              Cars under
use targeted marketing tactics to    business.”                                             Lesson 6 in this
reach this segment of members          In order                                             report suggests
and potential members with           to create that mutual value,                           some avenues
information about new loan           Weiser found that more than                            to explore…
programs designed especially for     two-thirds of the companies                            perhaps just to
them.                                that had successfully tapped                           learn how this
  Even as credit unions use          underserved markets had                                market works.
risk-based pricing, non-prime        “formed a partnership with an          Interestingly, there was no
borrowers have access to             organization that brought new        mention in the surveys of peer-
relatively better deals than prime   knowledge, skills, resources,        to-peer (P2P) lenders (e.g., Zopa
borrowers could receive at credit    or connections to their effort.       and Prosper) which present a
unions when compared to their        Frequently, these organizations      largely unanswered challenge
alternatives. Case in point:         were drawn to working with the       to credit unions. Perhaps there
  u During the interest rate         companies because they were          is room in the marketplace for
environment of late 2006 / early     seeking to create community          a “mutual fund” model for P2P
2007, non-prime borrowers had        benefits rather than trying to        lending where credit unions
access to 17% auto loan rates        make a profit themselves.”            would offer the underwriting
at credit unions. Other auto           During the course of this          technology and a sophisticated
lenders were charging non-prime      project, it became apparent that     web application interface. The
borrowers 25% or more.               not-for-profit credit unions that     interface could provide potential
  u At the same time, prime          developed non-prime auto loan        investors with underwriting
borrowers had access to 6% auto      programs tend to rely on business    information. Investors could
loan rates at credit unions. Yet     partnerships for integral program    then build their personal loan
auto dealers and other lenders       components. Those businesses         policies (e.g., two years of
were enticing prime borrowers        utilized most frequently have been   employment, credit score above
with financing as low as 0%           profiled throughout this report.      600, etc.). Credit unions could
(under certain conditions).            The most popular partnerships      originate and service the loans.
                                     regarding non-prime auto             This would be an appropriate
Partnerships with Product/           loans are for providing financial     activity for a CUSO.
Service Suppliers                    counseling. More than 85%              Overall, credit unions have a
  John Weiser, author of             10
                                                                          plethora of partnerships to explore
                                        John Weiser, Michele Kahane,
Untapped—Creating Value                                                   and consider, including those
                                     Steve Rochlin and Jessica Landis,
in Underserved Markets10,            Untapped—Creating Value in           designed to share expenses, share
conducted seven years of             Underserved Markets, 2006.           knowledge, and build referrals.



                                     Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders     23
         Concluding Comments

        Part of the excitement of            But make program changes             credit union services to markets
      working with emerging markets          through policy, not through drift.   previously served by sub-prime
      is that no one has all the solutions   Once you have a policy in place,     lenders:
      for success.                           follow it or revise it.                u “We have reduced our denial
                                               NCUF Auto Loan Survey              rate by 50% in the last six
      Experiment!                            respondents overwhelmingly           months.  ”
        Much of the current work is          agree that once you stretch the        u “Members are grateful to have
      experimental.                          boundaries, you “don’t lend          a low-interest loan. ”
        “We built it, but they didn’t        outside of policy.”                    u “It is a business strategy that
      come” is an all-too-common               One credit union several           both fulfills our social mission and
      excuse for credit unions that          years ago started offering            has a positive financial impact to
      have tried to enter new markets.       auto loans with an escrow for        the credit union.  ”
      Experience shows that account          savings. Members’ response was         u “We find that low-income
      acquisition is the hardest part of     extremely positive. However, the     members have a great sense of
      the process of expansion.              implementation had a small flaw:      pride when they commit to these
                                             the escrows could be breached        loans.”
      Use Failure as a Path to Success       for unusual car expenses or            u “People with low credit scores
                                             down payments with approval          who do get a loan here tend to
        Among credit unions that have        by the CEO. The credit union         come back to us first when they
      tried and eventually succeeded, a      found that escrow withdrawal         are car shopping again.  ”
      familiar theme is, “It turned out      management was taking a                u “We realize that when we help
      differently than I imagined – but       significant amount of time,           these type[s] of members, they will
      it was worth it!”                      decided that the program was not     be loyal forever.”
        Make sure to think of each           a full out-of-the-box success, and
      product as an experiment that          dropped the program rather than
      provides data about what works         investing in modifications and
      and what doesn’t. This way, no         improvements.
      products end as failures—just
      opportunities that open in             Set Limits
      hitherto unexpected directions.
                                               Starting out, credit unions
      Revise, Don’t Reverse                  should consider setting portfolio
                                             limits, perhaps based on capital
        Nobody gets a new market right       and staying within agreed
      on the first try. You must allow        parameters until the institution
      time to track outcomes and to          has gained experience.
      revise policies and procedures.          Set aside a loan loss reserve
                                             for the program based on your
Strategize...                                board’s perception of the value
                                             of the experiment and the risk
u Strategize at the board level              capacity of the credit union.
u Philosophical change from                    Set a sunset date on the product
 “the old days”                              with a specific date to present
u Define your appetite for risk               new data and revised proposals to
u Get buy-in from front line staff           the board.
u Goals:
 - Live your mission                         Reap Rewards!
 - Serve more members                         Besides reaching new members
 - Increase loan/share ratio                 and achieving financial success,
 - Increase net yield on portfolio           many credit unions rejoice in the
 - Develop loyalty                           positive member comments and
                                             experiences when they deliver


 24   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  Next Steps

  The word “opportunity” came
up many times in the surveys
and interviews for this report.
What can be done to move credit
unions to expand non-prime used
auto lending to build net income
and to serve members by giving
them a substantially better deal?

1) Get the Word Out!                               spot for photo
  Share this report with credit
unions. The National Credit
Union Foundation and state
credit union leagues, through
the REAL Solutions® program,
can market this report directly
to credit unions and to the trade
press, speak on this issue at
conferences, and feature these
ideas on their websites. A short
brochure and PowerPoint would       platform that would match credit       credit union members have, and
be useful.                          union products to non-profit            build a project to design products
                                    client needs.                          to meet these needs. Products
 A bolder approach would be to                                             that appear to be on the close
build a Steer Clear nationwide      5) Document Results                    horizon for emerging markets
branded product that gives credit     Collect data to document and         include prepaid cards, mortgage
union identity to non-prime used    analyze credit unions’ non-prime       triage products, and micro-
auto lending.                       used auto lending. Organize a          enterprise.
                                    pilot project to study in detail the     Opportunities to increase
2) Build a Toolkit                  results and profile one or more         market share and vehicle loan
                                    credit unions.                         volumes, while fulfilling credit
  Operationalize the research.                                             unions’ mission to improve the
Build a “How to” toolkit. Make it
easier and quicker to implement     6) Design New Non-Prime                financial situation of people of
non-prime used auto lending.        Products                               modest means, should drive
                                                                           credit unions to help car buyers
This toolkit would delve down         Research other products that         “steer clear” of predatory loans.
deeper into each of the seven       could be added to the non-prime
lessons.                            portfolio of credit unions. For
                                    example, the REAL Solutions®
3) Fill in Gaps                     process includes original insights
  Encourage vendors, including      into financial markets (e.g. the
CUSOs, to fill in the product        value of emerging markets),
gaps: insurance, loan guarantees,   research on opportunities in
automated underwriting,             those markets, identification of
secondary market, etc.              credit unions already engaged
                                    in best practices, and (working
4) Replicate and Collaborate        through the leagues) sharing
                                    product approaches and case
 Identify suitable partners and     studies with credit unions
build a replicable model for        interested in implementing new
partnerships with non-profit         products.
car programs. Collaborate on a        Determine what other needs


                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders      25
       References

      Annie E. Casey Foundation. Pursuit of the Dream: Cars & Jobs in America. Documentary DVD. February
     2008. http://www.aecf.org/MajorInitiatives/FamilyEconomicSuccess/PursuitoftheDream.aspx

      Nastars, James A. 2007. Analysis of University Federal Credit Union’s Sub-Prime Lending Program.

      National Economic Development and Law Center (NEDLC), and the Annie E. Casey Foundation. June
     2007. Low-Income Car Ownership Programs—2006 Survey.

      Opportunity Cars Resources. http://www.opportunitycars.com/Articles/index.htm.

      Schneider, Rachel and Arjan Shutte. 2007. The Predictive Value of Alternative Credit Scores. November
     26. Center for Financial Services Innovation.
      http://cfsinnovation.com/research-paper-detail.php?article_id=330262

      Sutton, Remar. April 2007. Car Financing for Low and Moderate Income Consumers. The Consumer Task
     Force for Automotive Issues, and The Aspen Institute.

      The Mobility Agenda—Car Ownership and Financing. http://www.mobilityagenda.org/carfinancing

      Waller, Margy. 2005. “Auto-Mobility: Subsidizing America’s Commute?” Washington Monthly. October




26   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
  About the Author

  William Myers is Senior Fellow of the Aspen Institute,
focusing on the Economic Opportunities Program. He
also serves as a Field Coach for REAL Solutions®,
the signature program of the National Credit Union
Foundation.
  Mr. Myers founded Alternatives Federal Credit Union
and was its CEO through mid-2007. From its inception,
Alternatives successfully focused on serving emerging
markets through innovative products and partnerships.
Noted innovations include a volunteer income tax
preparation site, five youth credit union branches, small
business training and lending, volunteer-staffed financial
planning, and Individual Development Accounts.
  Mr. Myers continues his work researching, consulting,
and speaking on innovative product design and
partnerships. His most recent projects include payday
lending models, pre-paid cards for emerging markets,
a scale and sustainability study, and a pilot using back-
office consolidation as a merger alternative.
  Mr. Myers is a graduate of Cornell University. He
has twice co-facilitated Credit Union Development
Education, the training program funded by the National
Credit Union Foundation to teach cooperative principles
and credit union values in the modern marketplace.
  He has served on the boards of the National
Federation of Community Development Credit Unions
and the Opportunity Finance Network. He has also
served three initiatives of the Credit Union National
Association: the Federal Credit Union SubCommittee,
the Renaissance Commission, and Project
Differentiation. And he is currently the List Manager of
the Community Development Banking listserv.


                                William Myers




                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   27
       Appendices

     Survey Invitation Letter
      As part of a pilot program involving the National Credit Union Foundation’s
     (NCUF’s) REAL Solutions® program, The Annie E. Casey Foundation, and
     The Aspen Institute, we are surveying credit unions for their innovative work
     with low credit score auto borrowers. Working together, we believe we
     can substantially increase auto lending to low-wealth and modest income
     working families and grow credit unions.

       We appreciate your assistance in helping us recognize the innovative work
     you are already doing by taking less than 10 minutes to complete this survey
     at http://tinyurl.com/2x3heh

      Thanks for your continued support of the National Credit Union
     Foundation and REAL Solutions® .

     William Myers,
     Field Coach, REAL Solutions®
     Senior Fellow, The Aspen Institute
     wmyers@realsolutions.ncuf.coop
     (607) 227-0934




28   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
Results and Verbatim Comments

Credit Union non-Prime Auto Lending Study
Responses through 3/10/2008

Name and Contact information.
                        Response    Response
Answer Options           Percent     Count
Your Name:                99.6%       246
Your Title:               98.8%       244
Your Credit Union:        98.8%       244
Your EMail Address:       99.2%       245
Your Phone Number         98.0%       242
                 answered question       247
                   skipped question        4




  The verbatim comments that appear on the following pages have been reproduced without editing.
This is meant to ensure that all survey respondents’ thoughts are conveyed to you exactly as they were
communicated to us.




                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   29
     What underwriting criteria have allowed
     your Credit Union to safely extend its
     lending to low credit score borrowers?
                                                          Response            Response
     Answer Options                                        Percent             Count
     Good payment history with the CU                       82.7%                 206
     Good payment history on auto loans                     64.7%                 161
     Strong employment                                      62.7%                 156
     Payroll or other automatic payment                     59.4%                 148
     Credit Scores below 620                                49.0%                 122
     Lower credit scores require a higher down payment      41.4%                 103
     Higher equity ratio required                           38.2%                  95
     Low unsecured debt                                     36.5%                  91
     Offer share secured loan instead of auto loan          26.1%                  65
     Advance money down in CU savings account               12.0%                  30
     Length of membership requirement                       12.0%                  30
     No credit score required                               11.6%                  29
     Lend on ITIN                                            6.0%                  15
     Internally generated credit score                       4.0%                  10
     Other (please specify)                                 26.9%                  67
                                                   answered question                    249
                                                    skipped question                      2


     - A partnership with a non-profit orgagnization        - Checking relaltionship.
       called BonnieCLAC which provides assis-
       tance in locating cars, counseling to borrowers     - Common sense
       and a partial guarantee to the credit union in      - co-signer
       the event of a deficiency after reposession
                                                           - CO-SIGNERS
     - All of our Loans are risk based priced.
                                                           - Credit Counseling prior to close of loan
     - Alternative payment histories, landlord, length
       of residency, employment                            - CUNA Mutual Lender Protection
     - automatic payments strongly encouraged, but         - CUNA Mutuals Lender Protection Program
       not mandated.
                                                           - Detailed information about the collateral in-


30   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 cluding taking a picture.                              no purpose other than the pricing bases for the
                                                        loan.
- excellent disposable income and debt to in-
  come ratios                                          - Low credit scores require a co-maker or
                                                         shorter terms.
- go over their credit report with them. In visiting
  with them, we get a better understanding of          - May offer a co-maker if first auto.
  their intent to pay. Sometimes we require a
  small loan history first.                             - May require a qualified co-signer.

- grant unsecured consolidation loan for col-          - May require guarantor. Also will not finance
  lection items and or to lower other payments           sales tax.
  to make loan possible to be within debt ratio        - Min credit score requirement is 580. We can
  limitation.                                            make exceptions when some of the above ap-
- Higher lending rates in a risk based program.          ply and with management approval.

- If a member has a plan for a major                   - Minimum length of residence, income verifi-
  purchases,and wants to reduce the amount               cation on all loans, minimum 3 references, If
  of the financed by the credit. We offer special         BK, no derogatory after BK, no more then one
  share accounts for that purpose.                       repo/foreclosure, length in file 9 months, no
                                                         tradeline greater then $5000 derog in last 12
- If no credit score, then we ask for about an           months, tax liens $2500+ must be in repay-
  80% LTV if no guarantor/co-maker is possible.          ment, one year paid as agreed on a trade or
                                                         auto, no private party sales and minimum
- Insurance for defaults on lower scores                 $500 down pmt.
- It is really a combination of the factors listed     - A program where new autos are deeply dis-
  above. I’m not sure this is a clear picture. One       counted by dealers which creates equity for
  person does not have to have all the factors I         the member along with extended warranties
  checked.
                                                       - Our underwriting guidelines still allow a num-
- Just providing opportunity. Each person is dif-        ber of variables that - when added together
  ferent - may have short term or long term em-          - enable us to offer collateralized loans to
  ployment. May have large or little down. May           members that have had credit problems in the
  have some good credit or none at all. May be           past -- In other words, good seniority, length
  entering credit world or in it for 20 years. All       of time with us, member’s willingness to take
  depends upon person - but providing chance             “ownership” (such as a good downpayment),
  is what they need.                                     etc. will allow the loan officer to make a posi-
- Lender’s Protection                                    tive determination on the loan.

- loan officer underwriting training to mitigate        - Parent/guardian cosigner if NO credit Low
  risks                                                  credit scores due to BAD credit, we counsel
                                                         them how to improve their score but do not do
- loan officers decision loans based on mem-              the loan.
  ber’s income to debt, time of employment and
  residence, credit history trends, relationship       - Payroll or automatic payments are voluntary
  with cu, and collateral. beacon scores serve           and can be stopped at anytime. We do not
                                                         weigh these payment types in our underwrit-


                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   31
      ing. We also won’t usually finance add-ons              can determine whether the mbr has always had
      such as MBI, GAP. We look for a strong LTV             struggles or whether it was a more recent issue.
      ratios so if we have to repo the vehicle, we are
      more apt to sell it with little or no loss. Also      - This is a hard question to answer. When we
      with thinking future repo, we look to see how           evaluate a low FICO member, we look a the
      attached they are to theie community. If they           specific circumstances of each member. So
      have been established in their community for            depending on the member, we may request
      some time and have family/friends/work ties to          use one or more of the requirements listed
      the community, they are less apt to skip.               above. . IT is also important to note that we
                                                              must separate between a member with a low
     - Purchase a vehicle that is make sense for the          FICO and a low-wealth/modest income fam-
       borrower.                                              ily. A low FICO is generally one that has not
                                                              paid their bills on time. Most low-wealth/mod-
     - Reduced LTV through a larger vehicle down              est income people have either no FICO score
       payment with savings (member “buy-in” to the           because they lack any traditioanl debts or have
       vehicle).                                              no Social sec. number.
     - Require collections to be paid; 6-12 mo. good        - Thoroughly understanding why the credit score
       payment history required on all credit obligations     was low and taking into consideration how it
     - Require minimum 2 open tradelines with I1/R1           may have improved and what plans were in
       status and must be current for last 6 months.          place on the part of the member to improve it
       Minimim credit score of 500. Minimim annual          - to obtain another loan with CU the mbr must
       income of $20,000. We offer 100% financing              have a positive payment record of 12 mo. or
       on a $15,000 car, plus tax, Warranty and GAP.          mot to receive and unsecured loan.
       No cash down required. We limit term to 48
       months.                                              - Use non-traditional credit score from Trans Union

     - Requiring risk mitigating products such as           - use of Auto Title deposits to offset higher risk
       Default Protection.                                    exposure also, direct verification of employ-
                                                              ment, residence and other non-traditional
     - RESIDENCY STABILITY NECESSITY VS.                      credit references
       LUXURY AUTO INSURABILITY DEBT RA-
       TIO CO SIGNERS                                       - We also look to see if the member owns a
                                                              home.
     - risk based lending
                                                            - We combine our internal signature value
     - «risk based lending imple- mentation                   taking into consideration if the member has
     - Risk based pricing                                     gone through our financial education program.
                                                              Length of time on job or in the same field is
     - Special policies for credit scores in the D and        considered. How long they have lived at their
       E tier.                                                residence is taken into consideration, income
                                                              and some other things in addition to collateral
     - Stability in residence and employment. Struc-          value. The higher the risk, the shorter term of
       ture based on risk - less risk = less structure.       the loan. co-signers are also very good.
       high risk requires more structure to loan. We
       also track mbr’s credit score twice a year and       - We do not have a loan program specifically for
       can trend their performance over 5 years. You          low beacon scores. We do risk price our loans,


32   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 so members with a lower beacon naturally have         - We have used non-traditional credit in the
 to pay more down to obtain financing.                    past. We request receipts from rent, layaway
                                                         payments, utilites, etc.
- We do not make loans based on Credit Score
  alone. We look at the “whole picture” when           - We just rolled out Lenders Protection through
  making a credit decision.                              CUNA Mutual to help better serve these mem-
                                                         bers with their automobile financing.
- We frequently lend to persons with scores
  below 600. We rely on a strong employment            - We look at the overall relationship with the
  history (most of our members are Federal em-           Member. How long have they been a member,
  ployees) and a debit ratio that may not exceed         previous loans that paid as agreed, checking
  45% of gross earnings. Most of our members             acct.,direct deposit are all positive factors in
  elect to repay via payroll deduction--although         building low scored members.
  we do not require it, nor do we make it a con-
  dition of the loan. We choose not to do this         - We pay special attention to stable employment,
  because persons frequently transfer to another         debt to income ratios, and loan to value.
  Federal facility and payroll deduction does not      - we qualify our borrowers on an income to debt
  automatically continue if they leave.                  ratio. We do not use risk base lending prac-
- We give board -appointed loan officers flex-             tices at this time.
  ibility to look for ways of approving loans. We      - We underwrite all high-risk laon with Default
  have no hard and fast rules for credit score or        insurance from Lender’s Protection.
  debt ratio.
                                                       - When low scores are a result of lack of credit
- We have a “Savers” loan, which the member              history we have used alternative sources to
  puts 10% of payment into a div baring account,         document payments as well as documenting
  which is secured until the loan is paid.. This         diplomas from college graduation.
  may allow no co-signer, and a reduced rate

- We have a program referred to as our Basic
  Transportation loan. It is designed to help
  members with lower credit scores have trans-
  portation to and from work. Max loan amount
  is $7500 and we limit the mileage on the
  vehicle to 75,000 miles. We will also include
  in the loan amount six months insurance pre-
  mium if needed.

- We have also implemented a very competitve
  risk-based lending matrix.

- We have developed a program that requires
  minimum length of employment or member-
  ship, together with non-traditional personal
  attributes (including a background check) in
  exchange for a dependable vehicle (vehicle
  limitations are part of the program) at an afford-
  able price and an affordable rate of interest.


                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   33
     Do you assist members in finding a car?
                                                     Response                 Response
     Answer Options                                   Percent                  Count
     Agreement with Local dealer                    59.6%                         68
     On line car buying                              37.7%                         43
     Car sale through rental agency                 35.1%                         40
     Own used car lot                                2.6%                          3
     Own a Dealership                                0.9%                           1
                                           Other (please specify)                 105
                                           answered question                                     114
                                             skipped question                                    137



     - a Special program involving dozens of local          and introduced a program called SmartBuys.
       dealerships.                                         The program is specifically targeted to low-
     - Agreement with Enterprise Car Sale                   middle income Members to assist them with
                                                            locating a reliable and economical car. I’d be
     Auto Advisor Program                                   happy to discuss further if you are interested.
     - Auto Advisor service through third party            - ___ “best price” and “best dealers” service

                                                           - Counsel members and also use a car buying
     - auto advisors                                         service
     - Auto broker service                                 - Credit Union Direct Lending
     - Auto Broker utilized for the last 20 years!         - CU Direct Lending, Autoland, local auto finder
     - auto buying service                                 - a local company where several credit union
     - Auto Expert                                           send reposessed vehicles.

     - Auto Sales by Dealers                               - CUDL

     - Car buying service companies (discounted            - CUDL service
       pricing): United Buying Service Motor Vehicle       - Direct our members
       Certification Program
                                                           - F2F CUDL on website
     - Car buying service through CU owned CUSO
                                                           - Fleet Dealers in our area
     - Car buying services
                                                           - Generally speaking there is not enough time
     - Car sales through sales agency. Auto buying           in a day for credit union loan officers to get in-
       service. We recently partnered with Enterprise


34   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 volved in the car buying process for a member,        - Note: Used Car Lot: We have an agreement
 but they can certainly advise them to go any-           with a local dealer at our headquarters location
 where except a dealership for the best deal.            to sell our repos and their good used cars.

- Have refferal program                                - Occasionally we sell repos because we offer
                                                         one rate financing versus risk based on those
- If a member requests our help, we will speak           loans.
  to the car dealership in their behalf and attempt
  to negotiate the sale. We have written agree-        - On-line resources
  ments with a few area dealers. However, we
  will personally speak to the sales representa-       - Only through Indirect relationships
  tive at any dealership. Whether we’ll intervene      - Our indirect lending department will assist
  in a sale depends on how the car has been
  priced. Sometimes is so high above “retail”          - own a dealership ???? not sure what that
  that we can’t stand it, so we’ll call and say “can     means
  you drop the price?” They usually do.
                                                       - Partnership with social service agency to pro-
- Indirect auto program                                  vide financial counseling
- Indirect Lending CUSO                                - use Members Auto Source - Auto Purchasing
                                                         Service through a FCU’s CUSO.
- Indirect Lending through Members Financed
  Autos                                                - pre-approvals and assist our members with
                                                         vehicle value information before they go to
- Indirect Lending with dealerships, Auto                dealership.
  Wholesale Direct Auto Brokers
                                                       - Pre-arranged pricing and auto locating through
- member finds auto                                       car-buying services and buyers club
- N/A                                                  - refer to local smaller dealer that sell for less
- indirect relationships with all area dealers that    - Re-marketing of previously financed
  will allow the member to contract at the dealer-       vehicles(repo’s) to buyers who do not meet
  ship.                                                  regular guidelines.
- no (13 responses)                                    - The credit union works with an Auto Buying
- No we don’t.                                           Broker Service

- No, we currently have no affiliation with any         - the local dealer offers vehicle buyer services in
  type of dealership in the area. Most members           our branches and is CU owned
  purchase cars from the owners.                       - a program which assists members with pre
- Non profit BonnieCLAC does this for their               negotiated prices and follow up on pricing.
  clients. For those clients who have not com-         - Utilize CUDL’s Auto Smart program to help
  pleted their counseling program they have              borrowers identify potential dealers and ve-
  “loaner” cars that can be used in the interim.         hicles
- Not at this time but will by 2nd qtr 2008.           - We also have an Auto Resource Center which
                                                         is a vehicle locate service. We have strong re-


                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   35
      lationships with many area dealers and negoti-        is worth.
      ate deals for our members. We also sell our
      off lease vehicles and have a strong relation-       - We have a car buying service for our members
      ship with a used car dealer.                         - We have a car buying service that assists
     - We are a large indirect lender with over 250          members in locating a desired car. We use
       participating dealerships.                            dealers that are part of our indirect network
                                                             and have agreed to give our members the best
     - We are in the developing stages with our              deal possible.
       indirect program to offer online inventory with
       specific dealers                                     - We have a car buying service.

     - We assist informing member with information         - We have a partnership with Enterprise. There
       as to the value of the vehicle. NADA & New            are several sales lots in North Carolina that our
       car book.                                             members can visit.

     - We do business with Enterprise (Rental),            - We have a program that includes dozens of
       where they offer no haggle buying and under           used and new dealerships allowing purchases
       Kelly Blue Book prices. The credit union will         at cost plus.....
       also take 25 basis points off of the base rate      - we have an auto buying service at no cost to
     - we do carbuyer workshops in English and               members.
       Spanish, and advocate on their behalf. For          - We have an Auto Scout,the member gets
       example, we recently filed a NYS Attorney              preapproved lets us know what they are look-
       General complaint against a dealer who we             ing for and he go looking and negotiate for the
       believe is “packing” extended warranties, etc.        member.
       on sales to Hispanic immigrants
                                                           - We have an Auto Scout,the member gets
     - we do not assist in finding a car                      preapproved lets us know what they are look-
     - We do not assist members with vehicle loca-           ing for and he go looking and negotiate for the
       tion services. Our staffing does not allow for         member.
       that.                                               - We have an indirect program with a local credit
     - We do not assist the member in finding a car           union. We purchase loans from them.
       but we do review purchase agreements and            - We have our own in-house auto buying ser-
       will help negotiate sales price, especially with      vice
       dealers that have excessive mark ups which
       impacts LTV.                                        - We have referred members to a “car broker”
                                                             who will help with purchase of japanese autos.
     - We do offer a car buying service through an           He is known to many members and staff and
       auto broker that members have an option of            has done a great, affordable service, so if the
       using for a fee.                                      members asks for help we will suggest they
     - We do refer to local dealer, however, do not          contact this person. We also know certain
       have a written agreement.                             dealers where members have been ripped off
                                                             by poor quality cars and we will tell members if
     - We find the value of the car thru NADA and             we see them looking at a car from one of those
       ensure that they do not pay more than the car         dealers - warning them of our concern and


36   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 the experience of other members. We also            - work with the member’s debt ratio and budget
 will condition some loans on having the car           to suggest a sales price and payment they can
 cleared by one of two local mechanics that the        afford
 CU trusts to give an assessment of the vehicle
 and the purchase price. Members have been           - Yes, as much as possible. We provide them
 very happy with this service. We also let mem-        with the values of the vehicles they are looking
 bers look at Consumer Reports information on          at. Assist them with the negotiating process,
 vehicles and talk about and share information         sometimes a little too much! We also have a
 on gas mileage.                                       few local dealerships that sell their vehicles at
                                                       less than retail and we will tell members the
We may recommend dealers that we have an               names of the 2-3 dealerships that do that.
Indirect relationship with, but we do not assist
members in finding a car.

- We partake in CUDL....so our members fi-
  nance at the point of sale....we drive our mem-
  bers to our dealer partners

- we participate in an auto buying service,plus
  we have relationships with local dealers

- We promote a program, which is the Credit
  Union Systems’ indirect lending program.

- we publish our CUDL Dealers on our website.

- We require that they huy the car through one
  dealer.

- We tried agreements with local dealers and
  could not make the program work. If the
  credit union could have an ownership inter-
  est in a used car lot it would solve most of the
  problems.

- We use an auto buyer- independent third party

- We will help the member with “on-Line” price
  assessment of the car they are trading and the
  car the are purchasing so that they can negoti-
  ate intelligently.

- We will help them to value cars they do find.
  In one case, with a low-funtioning member, my
  loan processor did find a car for them in their
  price range.

- We work with Enterprise and Carquotes.




                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   37
     What Risk Mitigation techniques do you employ?
                                                                       Response           Response
     Answer Options                                                     Percent            Count
     Limit loan to Blue book value                                    65.6%                  160
     Set maximum loan duration based on age of car                    62.7%                  153
     Verify the information provided.                                 50.0%                  122
     Schedule payment when member gets paid                           41.8%                  102
     Require minimum time at job or in field, at residence, etc.       38.5%                  94
     5 day collection call                                            27.9%                  68
     Set portfolio Loan Limits                                        24.6%                  60
     Make sure they carry the member elect insurances, etc.           24.2%                   59
     ProActive Collateral Recovery System                             14.3%                   35
     Regularly analyze members’ credit scores                         11.5%                   28
     Repo at 30 days                                                  10.7%                   26
     Repossess the vehicle at 30 days late                            10.2%                   25
     Forced savings for repairs                                        2.9%                    7
                                                                      Other                   61
                                                               answered question                    244
                                                                skipped question                      7



     - 60 DAY REPO                                         - Any high risk loans are “queued” to the collec-
                                                             tion department to be followed on a regualar
     - 7 day collection notice, repo at 45 days              basis for any signs of “stress”. Collection
                                                             efforts would begin immediately once the loan
     - Active collection techniques employed by              becomes delinquent.
       loan resolution team understanding reason for
       delinquency, strong closing of loans by FSRs,       - Applicants with less than 12 mos credit must
       emplying solutions to work out of problem situ-       be on job at least 6 months and are limited to
       ations, close monitoring of early default loans       a loan <= 60% annual income and 80% LTV.
                                                             These applicants and applicants with FICO
     - All C & D borrowers receive collection calls on       scores <620 are also limited to a 100k mile-
       Day 1. Most other mitigation techniques sug-          age cap. Employment/Income is also verified
       gested above are employed, but none are set           on these applicants.
       by policy.
                                                           - As mentioned in #2 - we track scores twice a
     - Analyze the financial situation of the member.         year and if the mbr is trending down - we will
       Debt to income ratio not to exceed 40% of             monitor the accts more closely.
       their monthly income.


38   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
- Borrowers must have completed Financial Fit-         age of car, require collision and comprehen-
  ness training course                                 sive on auto’s over $5k, member employed 90
                                                       days of more unless job change for better pay.
- Budget and action plans, financial education
  classes                                             - Limit to black book values as they are more
                                                        accurate.
- Call at 14 days. Grace Period is 15 days
                                                      - Loan only 90% of value on credit score 619
- Charge fee on certain credit rebuilding loans         and under

- Collectin notices genrated daily at 5, 15 and       - Maximum debt/income ratio; require auto debit
  25 days CUNA Mutual Lender Protection                 for payments
  Collectin Policies based on rehabilitation first,
  recovery second                                     - More aggressive collections but not abusive
                                                        repo rules. These members have a higher
- Collection Call at Day #10.                           than average luikelihood of incurring financial
                                                        glitches but will be the most loyal as we prove
- Collections department personnel speak to             that we are for them...
  them. We tell them about the Credit Union
  difference and that we are taking a chance on       - Must be acceptable collateral wiithhin policies.
  them that other FI’s would not take.
                                                      - A WELL STAFFED AND PROACTIVE COL-
- Debt structure considered e.g. retail v. install-     LECTION DEPARTMENT.
  ment, capacity, previous borrowing experience
  for similar loan request; negative amortization     - Price appropriately for the risk.
  mortgages, and a keen emphasis on “re-
  serves”!                                            - repo at 60

- DIRECT DEPOSIT OF INCOME                            - Repo at 60 days. We normally do not allow
                                                        redemption after repo unless they pay loan off
- Hard close.                                           in full. (Does not apply to Reese-Levering Act
                                                        vehicles)
- Have a proactive collection department
                                                      - Repo collateral @ 30 or 60 days depending on
- Here again each individual request will deter-        if member is working with us or ignoring us
  mine conditions.
                                                      - Repo is set to occur if loan is delinquent 60
- Limit Grade D to a % of capital. Price accord-        days or more. The blue book value is limited to
  ing to score. The lower the score, the higher         the trade in value of the vehicle.
  the rate.
                                                      - require 10% of total loan in shares
- Limit loan to a percentage of NADA value, dif-
  fering by credit tier                               - REQUIRE loan Default Protection

- Limit loan to black book value                      - Require payroll direct deposit with automatic
                                                        payment distribution. GAP Insurance on new
- limit loan to retail of NADA, duration based on       cars.


                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   39
     - run credit reports on all loans and questions          COLLATERAL PROTECTION INSURANCE
       mbr if need be about the report (things being          POLICY VIA CUNA.
       pd in full or still owing) Tax leins, judgements,
       repo’s , foreclosures and bankruptcy                  - We found that a large precentage of our de-
                                                               linquent loans were young people just starting
     - See answers to number 3. Complete applica-              out, now we always figure in a rent payment
       tions with references - especially for first time        even if the member is still living at home. That
       borrowers. We also do monitor first-time bor-            way if they move out, they should be able to af-
       rowers and first payments very closely and will          ford the vehicle and the rent.
       make calls to them until we see regular pay-
       ments occuring, preferably thru direct deposit        - we have a first time buyers program
       and automatic payment.                                  that limits amount financed,down pmt
                                                               requirements,length of emp,references, letter
     - Set maximum age and mileage of car.                     from emp and poi

                                                             - We have a strong loan closing and collection
     - Solid Co-Makers when needed.                            department but it is not one size fits all.

     - start repo at 30-45 days                              - we have the ability to use lender’s protection to
                                                               protect the loan if it were to default
     - Tiered pricing to offset our risk
                                                             - We use a credit bureau pre-approval to gener-
     - Until recently we did not offer a loan for more         ate the offers, using the criteria above in #3
       than 48 months if the loan was for less than
       $15,000. We offered 60 months if greater
       than $15,000. Now we allow our members an             - We use CUNA Mutual’s Lender’s Protection
       additional 12 months if they purchase GAP (at           Program
       $225) through us.
                                                             - We will collect by credit score in the very near
     - Used Vehicles - 100% Retail Value As Listed             future. Lower credit scores will receive quicker
       By The Blue Book                                        attention when collecting and repossessing.

     - Usually repo at 60 days                               - We will only lend up to 90% of the blue book
                                                               value.
     - Various others....LTV limits, term limits, no BK’s,
       POI etc....                                           - When we add forced placed insurance we
                                                               force member to increase their payment to
     - We do a 5 day collection letter for members             cover the cost
       who are C and D paper.
                                                             - work with members for payments when issues
     - We do collect higher risk loans differently than        create late payment, repo benefits no one.
       we do low risk loans. Much closer follow-up.


     - WE DO NOT RELY UPON MEMBERS TO
       GET CAR INSURANCE. ALL OUR AUTO
       LOANS ARE COVERED BY A BLANKET


40   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 Do you offer insurance coverages with
 the loan product?
                                                Response              Response
  Answer Options                                 Percent               Count
  Credit disability protection            90.8%                          218
  Credit life protection                  88.8%                          213
  Guaranteed Asset Protection             77.9%                          187
  Mechanical Breakdown Insurance          60.4%                          145
  Debt Cancellation                       11.7%                           28
  Assure insurance                         2.1%                           5
  Walkaway                                0.8%                            2
                               Other (please specify)                     18
                               answered question                                   240
                                 skipped question                                   11



- All of the above are available, but not required.       - Other insurance offered by the dealership.

- auto insurance                                          - our dealers can sel whatever backend prod-
                                                            ucts as long as the don’t go over our max
- Collateral Protection Insurance is all from               advances.
  CUNA!
                                                          - The dealers offer these products and we in-
- Credit Disability is member paid and the                  clude the cost in our financing.
  Credit Life is paid by the credit union up to
  $25,000.                                                - The life and disability protection is part of our
                                                            Debt Cancellation package.
- GAP Insurance
                                                          - These are offered through an arrangement for
- GAPP coverage                                             a discounted price from selected dealers

- Lender Protection                                       - We also implemented same loan payment with
                                                            or without insurance. We simply extend the
- Life and disability it is optional.                       term of the loan to cover the cost of insurance
                                                            protection. So far, members dont mind the ex-
- Loan protection for all members paid by credit            tra payments as long as the payment fits their
  union.                                                    monthly cash flow/budgets.

- no                                                      - We also offer GAP.

- none


                                        Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   41
     How do you market to potential low wage
     members?
                                               Response              Response
     Answer Options                             Percent               Count
     Encourage members to get CU               88.7%                     180
     financing first
     Recapture Loans (with member              28.6%                     58
     premium)
     First time auto Loan                      25.6%                     52
     Timely payment reward                      7.9%                     16
     Branch looks like a finance                 1.0%                      2
     company location (different
     branding than the credit union).
                                    Other (please specify)               53
                                      answered question                          203
                                       skipped question                           48



     - acquire many through indirect lending                ble financing a customer they can refer them to
                                                            us.
     - Applicants come through social service agency
       office                                               - Discounted rate for saving a certain amount
                                                             monthly along with the car payment.
     - Area used car dealers are aware that we have
       the best rates for high risk low-income borrow-     - Establish credit with secure products and
       ers and because they want to sell cars send           monitor payback period and start limits with
       applicants to us. All applicants must come into       low amounts!
       credit union for face to face interview with loan
       officer.                                             - financial education seminars

     - Basic Transportation Program is noted in our        - Hope you are not confusing the low wage situ-
       newsletters, brochures and website.                   ation with the low credit score one, we have
                                                             experienced many people who make a high
     - Constantly feature auto loans with rate price         wage and can’t manage their money leading to
       leader and deal locator service.                      a low credit score

     - Credit Union lobby,Newsletters,payroll insert,      - If a member has paid an auto loan with another
       Bulletin Board at work sites.                         financail institution “as agreed” for 12 mos., we
                                                             guarantee to refinance without a credit analy-
     - Dealerships know that if they are having trou-        sis.



42   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
- LCU has Modified Direct and Indirect relation-        being used for our Military members only.
  ships with Used Vehicle Dealers that are risk
  based priced for new and existing Members.         - Our members are Federal employees. Even
                                                       the loweset wage earning makes at least
- Loans to 16 year olds with parent/guardian           $25,000 annually.
  cosigner.
                                                     - referrals from other members
- Local dealers recognize our CU as one most
  likely/willing to help credit challenged borrow-   - REPOSESSIONS VERY VISIBLE AND AUC-
  ers                                                  TION ON OUR WEBSITE

- Lower interest rates                               - SCU has branchs inside several Wal*Mart
                                                       locations
- LOWER INTEREST RATES, AND INTEREST
  RATES NOT TIED TO CREDIT SCORE.                    - They actually seem to find us with little/no
                                                       marketing
- Make ourselves available for financing at the
  dealerships through our local Credit Union         - through used car dealerships
  Auto Loan Network - which requires the deal-
  ers to                                             - Various promotions have been held to encour-
                                                       age members to come in and meet with loan
- Marketing efforts are to total body of church        personnel to see if better payment terms can
  members as a whole. First time auto loans and        be offered through a refinance program.
  refinance of existing in addition to new/used
  purchases are pushed.                              - Via quarterly newsletters, inserts in mortgage
                                                       bills, in lobby displays, web site
- Most of our marketing to low wealth members
  is done through our Community outreach pro-        - we are constantly reaching out and looking to
  grams. We work with non-profit organizations,         improve marketing consistency in an effort to
  and political leaders to help us identify and        steer them clear of predators and get them out
  market to low-wealth and immigrant individu-         of bad loans when they don’t come to us first
  als.
                                                     - We do joint marketing with the non-profit
- Most of our members fit in this category. I do        agency, borrowers must be referred by them.
  email blasts to staff.
                                                     - We do recapture loans and are able to get the
- N/A                                                  member a better rate than they have else-
                                                       where.
- no special marketing. we use an outboand
  sales center.                                      - we don’t

- None of these...Encourage to get a garantor.       - we don’t have any special programs on our
                                                       indirect side for low wage....we do have limited
- Offer Auto Buying seminars to educate                loan amounts for our members who are col-
  members                                              lege students etc...these are all branch loans
                                                       though...not indirect loans.
- Our first time auto loan program is currently


                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   43
     - We don’t proactively market to this segment

     - We don’t specifically market to this area yet.

     - We have a branch in a non-profit cooperative
       that serves unbanked people.

     - We have trained our staff to conduct very in-
       dept interviews. Marketing pushes people in
       the door, the staff does the rest.

     - We mail a pre-approval letter to these mem-
       bers monthly

     - We offer discounts to members that pay satis-
       factorily when they pay off by reducing the rate
       by .25%.

     - We try to educate low wage members about
       how much car they can really afford.

     - We use a preselected list and market by invi-
       tiation only

     - we will refinance loan from other institution to
       lower payment without extending term if within
       book value

     - We work with 3 used car dealers in town who
       refer potential customers to us

     - when a mbr joins the CU we have a handout
       with all of our information about loans, check-
       ing, debt cards etc. If they come in asking
       about a particular loan we will explain to them
       what they would need to get the loan and if
       they are not able to get the loan we go over
       the credit report with the member to try to help
       them improve their score so we can help them
       the next time they come in.

     - When market, we market to all our members.

     - word of mouth mainly.

     - Word of mouth. Advertising in Hispanic mar-
       ket of radio and television.


44   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
Do you use partnerships to assist in
serving this marketplace?
                                           Response          Response
Answer Options                              Percent           Count
Financial Counseling                        85.4%                 88
Non profit partnerships                      29.1%                 30
Partner with mechanic for pre-               4.9%                  5
purchase inspection
                                 Other (please specify)           38
                                 answered question                     103
                                   skipped question                    148



- Accell                                             - If a members participates in the a Financial
                                                       Counseling Program, we offered a reduced
- again, we do carbuying workshops and finan-           interest rate on their loan (range .25, .50, .75
  cial ed at various partner locations                 or 1.00%). The rates are in a turn barrel and
                                                       the member is allow to pull one label which
- Balance                                              indicates the rate deduction they receive.

- BALANCE                                            - In the wake of current conditions, financial
                                                       planning seminars and materials are needed
- Balance                                              for all member segments!

- Balance                                            - In-house auto buygin service.

- Balance                                            - n/a (2)

- balance program                                    - No (9)

- Consumer Credit Counseling                         - None (2)

- cplc.org and its many service outlets.             - None of these...

- Federation’s PRIDE program supports with           - our financial counseling is done within the
  25% support.                                         credit union

- Good News Garage -Education on owning a            - PEFCU has there own Financial Couselor and
  maintaining a car includes practical session         is offered free to our membership.
  with mechanic.
                                                     - We have an inhouse community education


                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   45
      department

     - We Have Our Own Financial Counseling Pro-
       gram - Not Through A Partnership

     - We have our own financial counseling service

     - We partner with a company that provides free
       financial education and debt management
       counseling to members of participating credit
       unions.

     - We use the Balance program.

     - We work with the local Consumer Credit
       Counseling Services in the markets we serve
       as well as the Family Support divisions for the
       Bases we serve.




46   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
Has your low credit score auto lending program
been successful? What lessons have you
learned?
                                          Response           Response
Answer Options                             Percent            Count
Open Comments                            71.7%                   180
                                 answered question                      180
                                  skipped question                       71


- A need to price for the risk. A need to gain a      - Although we have had RBP for 10 years we
  firm commitment from the borrower at closing           have been doing risk base lending a short
  (i.e., the hard close). A need to collect aggres-     time, maybe 1-2 years, so we do not have
  sively, including repossession at no later than       alot of history to work from. I would say it has
  60 days. A need to monitor yield, delinquency,        helped but we will need 1-2 more years to re-
  charge offs, and net yield by individual paper        ally effectively measure the results.
  grade to ensure we’re pricing appropriate and
  can make adjustments to both pricing and            - Any lending program can be successful if you
  underwriting standards when necessary. Our            plan it correctly.
  portfolio yield is more than 120bp above our
  peers, and more than makes up for our above         - As successful as risk allows. Member educa-
  average charge offs. It is a business strategy        tion on credit scores, debt-ratios, auto buying
  that both fulfills our social mission and has a        and how to maintain a strong, positive relation-
  positive financial impact to the CU.                   ship with CU have mitigated risk.

- A strong loan closing is very important. Also,      - Average success. Had to quit CMG program
  we have a very aggressive collection program.         due to large losses. We see good results from
                                                        our first time buyers in our graduating senior
- Actually, we do not have any specific pro-             program.
  grames related to the low score members.
  The credit decision is done by an analyst who       - Continous monitoring of the lower tier delin-
  analyze them individually .                           quency performance and open communication
                                                        with our collections group to ensure that credit
- Admittedly, our “program” is not formal. We           granting guidelines are reflective of loss expe-
  look at each applicant’s qualifications, no            riences.
  matter what their credit score, and try to find a
  way to make the loan and educate the member         - Cover rent in debt ratio, have at least six
  when appropriate. The credit score is a tool          months of current job history, review credit his-
  used primarily for pricing, not decision-making.      tory with us, get co-signers, or extra collateral.
                                                        We also review credit after 6-12 months and



                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders    47
      will reduce interest rate if credit has improved.     a dealer take advantage of them up front. That
                                                            helps everybody from the start. -- The internet
     - Currently reviewing with potential of making         can be a very good tool and freind in todays
       requirements less restrictive.                       world.

     - Down payment requirement (10%) helps to             - Good returns. You must verify employment and
       offset some risk.                                     income if you are buying these loans on an
                                                             indirect basis.
     - Down payment should be required on ques-
       tionable loans. Shorter term limits depending       - Great success with low or no credit score ap-
       on the age of the auto being financed. Offer           plicants, specifically matricula and ITIN holders
       more education on the auto buying process.
                                                           - Has higher losses in the past but we recog-
     - Even though there have been some lates in the         nize this and limit the total outstandings in the
       past 10 months, we have not yet had a repos-          portfolio.
       session. Our portfolio contains over 100 mem-
       bers and $1.9 million.                              - I don’t think it is any more or less successful
                                                             than typical underwriting standards.
     - Extremely. We find it very important to accu-
       rately value the vehicle and to do a lower loan     - I have helped a number of credit unions
       to value than on our regular lending. We also         achieve success with high-risk auto lending by
       attempt to obtain as much cash down as pos-           training staff and management on how to do
       sible so the buyer has a vested interest in the       this lending well.
       vehicle. We have been doing this for a very
       long time.                                          - If the member has good job time & payroll de-
                                                             duction we usually will do the loan but watch
     - For us it’s important to have member loyalty          doing ACH Origination from their bank - do it
       to our CU and those members refer members             directly with the employer. Much better re-
       and some even co-sign to help newcomers. If           sults!
       we make a bad decision we tend to lose about
       $5K on our used car repos. Not sure we’ve           - if the member is “loyal” to the credit union, they
       been doing it long enough to be successful.           will pay us back and of course, if they have is-
                                                             sues, we will also work with them
     - Fortunately, we have had very good luck with
       our auto lending program. We find that low           - In 2002 - 2004 we participated in a lending
       income members have a great sense of pride            partnership with 2 auto dealers with rather
       when they commit to these loans. Our delin-           disastrous results. But we didn’t want this
       quency rate is less the 1%,                           experience to dampen our hopes to serve
                                                             our members so we now do our auto lending
     - Get them a payment they can afford. Get               program without dealer partnerships. If a loan
       them to take Mech. Breakdown Ins. (because            applicant has a low credit score we will work
       they cannot afford the repairs later). Make           with them to tell them what they need to do to
       them go through some Financial Counseling             qualify for a car loan - including letting us get
       to help understand the ramifications of failures.      to know them by becoming a active members,
       Start off into the vehicle at the reasonable          putting savings away to help towards a down-
       value. Help them make the deal and do not let         payment to give us a better LTV. If they have



48   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 a high debt-to-income ratio, we ask them to         - IT HAS NOT BEEN ENTIRELY SUCCESS-
 put the equivalent of the payment and insur-          FUL. ONE LESSON LEARNED IS TO BE
 ance in a savings account for three months or         WARY OF AUTOS REGISTERED OUT OF
 more to see what it’s easy to live without that       STATE. ANOTHER IS TO INCREASE THE
 money. This usually convinces the member              SHARE DEPOSIT REQUIRED, GIVEN THAT
 that perhaps they are better off without the car      AUTOS DEPRECIATE SO RAPIDLY. WE
 or that a smaller car loan would be better than       HAVE NOT GENERALLY DONE NEW CAR
 the one they were thinking about. The key is          LOANS, WHICH IS MAYBE A GOOD THING
 member education.                                     SINCE THE VALUES ARE HIGHER, YET
                                                       THE AUTOS LOSE FAR MORE OF THEIR
- It has a good ROA yet but the time employees         VALUE. TAXI LOANS, HOWEVER, HAVE
  spend collecting these loans has increased.          BEEN A BETTER BET THAN PERSONAL
  Direct deals are better than indirect deals and      AUTO LOANS.
  new members are definitely more risky than
  existing members when it comes to lower            - IT is beginning to be more now that we have
  scores.                                              closed some loopholes that have impacted our
                                                       losses significently...i.e. tighter policies and
- It has been marginally profitable. We are rais-       retraining loan officers. We will make to low
  ing rates on C, D, and E paper to shore up this      credit scores done in the member’s and credit
  market profitability.                                 union’s best interest.

- It has been moderately successful with a           - It is not uncommon for us to approve a vehicle
  higher reposession rate.                             loan for memebers whose score is below 600.
                                                       We look at their work history, their payment
- it has been successful because we monitor it         history with the credit union and their ability to
  on a a regular basis                                 pay. Most people in this category rely on their
                                                       vehicle to get back and forth to their job and
- IT HAS BEEN SUCCESSFUL FOR PUR-                      they will let their house payment get behind
  CHASES. IT HAS NOT BEEN USEFUL TO                    before they will not pay for their vehicle.
  TAKE OLD BEATERS FOR COLLATERAL
                                                     - Just returning. Lendr protection may be the
- It has been successful with delinquency and          key
  charge off %’s being better than industry. We
  did underestimate the collection efforts for our   - Just rolled it out within last 6 months. Volume
  higher risk paper and had to tweak those rates       is good, but portfolio has not matured enough
  up accordingly.                                      to determine if successful.

- It has been successful. We always educate          - Just started this past October.
  our members about credit scores & budgeting.
  Lesson: Closing the loan properly is a must.       - length of employment is a great mitigating fac-
                                                       tor and repayment of preceding loans with the
- It has not always been successful. Having the        credit union.
  member but some money down towards the
  vehicle is a plus. GAP insurance is a definate      - Looking closer at these deals and usually
  these days to have.                                  reviewed by more than one lender prior to
                                                       approval, remember that we are here to do



                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   49
      loans!!                                              - N/A

     - Loss ratios continue at the 3 - 4% level. More      - N/A
       than adequate to make this part of our portfolio
       productive                                          - Our Auto Lending it’s not successfull, because
                                                             we don’t have a demand for it. I think it has to
     - Low credit scores can be considered a relative        do with marketing, paper work, requirement
       term. We consider low 600-650. We don’t do            and convinience. I know you can go to a Car
       many of these loans as the member must also           Dealer and drive a car the same day. Taking a
       qualify under normal underwriting standards           loan with the credit union depends on the bor-
       (debt to income--etc.). However, the loans that       rowers, if they provide all the required docu-
       we have approved have all been successful so          ments, if the member qualify base on income.
       far.                                                  Overall, our auto loans are successful, but
                                                             don’t make tha many.
     - Low Fico scoring members must have a strong
       profile (CU relationships, job time/type, home       - OUR DELIQUENCY RATE IS LOW. WE
       time/type), and have proper cash down                 SEND REPO NOTICE EARLIER IF WE
                                                             HAVE THE TITLE. CARS UNDER $4000
     - Low scores are indicative of fundamental              ARE PERSONAL LOANS
       underlying issues. Financial education, action
       plans and tools such as our tracker loans ad-       - Our Members Have Been Happy To Have A
       dress the underlying causes making members            Car And We Have Been Successful In Repay-
       more likely to be successful. Without behavior        ment; Many Low Scores Are Related To Past
       changes, budgets and better planning, these           Credit Which Has Been Corrected
       loans will have higher losses making lending to
       this market not sustainable.                        - Our partnership with CUDL and Lender’s
                                                             Protection has been vitial to ur sucess as a top
     - Marginally Sucessful- Low Credit Members              lender in the NC marketplace.
       have their outlets for borrowing - It’s a tough
       job to convince them we are serious about           - Our program is approximately 7 years old. We
       saying “Yes” to them.                                 typically originate 50 or so each month. We
                                                             currently have about 5,600 on our books.
     - Members with very poor credit or no credit are        When the program was started, not enough
       extremely risky. The Credit Union must find            emphasis was placed on the member’s abil-
       compensating factors to make these types of           ity to repay. We tweaked that after about two
       loans.                                                years and required a Senior Vice President
                                                             approval if the credit score is below 540.
     - Moderately successful with Lenders Protection
       Program. We do not promote it but rather use        - Our program is less than 2 years old. Mem-
       it as a tool to make loans that we would not          bers are grateful to have a low interest loan.
       otherwise.                                            Delinquency has been very minor

     - Modest success.                                     - Our program provides rates based on credit
                                                             scores. members with 550 score or less
     - N/A                                                   require qualified comaker of 650 or higher or
                                                             100% share secured. Our members are also



50   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 counseled as to how to clear up credit report        - somewhat we must watch the credit scores &
 and how to save money.                                 unsecured debt

- Our teenage borrowers have gone on to be            - Somewhat, but not as successful as we had
  stable adult borrowers.                               hoped.d planned. This program has allowed
                                                        us to made loans to members previously
- Our terms for lower scores have higher rates.         denied. But, even with policy changes and
  For first time buyers, or those with three trades      assistance offered, we find that members are
  or less, we offer $10K max loan, with 10%             still making still making impulsive purchases
  down payment minimum. We can override the             and using payday. Therefore, continued
  max $10K loan with a Regional Director ap-            financial counseling is needed with emphasis
  proval. Enterprise has been a good partner in         on planned spending over impulsive and the
  assisting us with members who need reliable           value your credit union offers.
  vehicles within this price range or close to it.
                                                      - Stability of employment is major concern.
- Pretty much. We just scrutinize their applica-
  tion very carefully.                                - Stay within agreed parameters.

- Since we leave the door open to loan to             - Still a work in process - too early to evaluate
  anyone - regardless of their credit score - our
  loan officers have the authorization to meet         - Still to early to tell.
  member needs if the history of the member
  assures us that their adverse credit is not due     - The pre-close counseling includes awareness
  to lack of financial responsibility - but, due to      of what the financing means to them financially
  situations out of their ocntrol, such as illness,     and for the future...we commit that if they pay
  loss of income, etc. Therefore, over the years,       us, they can depend on future auto loans as
  we have built a reputation - both through the         long as we can see positive financial manage-
  membership and our indirect dealers - that we         ment efforts. They see us as a partner in their
  will not discount any application solely due          financial success.
  to their credit score. We will always consider
  “character” and circumstances before making         - the structure of the loan is important. Member
  an underwriting decision.                             needs to have money in the vehicle. We have
                                                        been able to save the members money when
- So far, so good. On the indirect side, we use         they initially had the loan financed elsewhere
  LPI - Lenders Protection(a CUNA insurance             and we can refinance that auto loan with the
  program) to assist in writing lower credit on         credit union. We normally can beat their rate
  that business.                                        by several basis points.

- So far. Most CU loyalists pay the credit union      - This is not a special program but an extension
  regardless of situation.                              of our philosophy of meeting members’ needs
                                                        and those of our community.
- Somewhat successful. People with low credit
  scores that do get a loan here tend to come         - To early to tell
  back to us first when they are car shopping
  again.                                              - to early to tell - looking for viability of high rate
                                                        lowering on successful payment history but in



                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders      51
      its infancy stages.                                   provide.

     - To-date it has been successful. We don’t have       - We do not have a long enough history to as-
       a lot of sub 620 credit score members but we          sess success.
       have tried to be more aggressive in this area
       -- trying to assume more risk. We have utilized     - We do not have a specific low score auto lend-
       risk based pricing and by being more aggres-          ing program, but it is certainly incorporated
       sive, we have reduced our denial rate by 50%          into our overall lending. We make sure all poli-
       in the last 6 mos.                                    cies are followed and want to see some equity
                                                             in the collateral and job stablilty. Income and
     - Too new to assess but originations have clearly       residence is always verified with current pay
       increase to D and E borrowers. Loss history is        stubs.
       needed.
                                                           - WE DO NOT HAVE A STRUCTURED PRO-
     - Toughest lesson is that you can’t simply say          GRAM.
       you’re doing risk-based lending. As a tradi-
       tional “A-paper” shop, we’ve found it difficult      - We do not offer a low score auto lending
       to change the mind-set of the loan decision           program!Our program has been successful by
       makers.     I would say that our low credit           portfolio analysis of response to FICO score
       score auto lending program is only marginally         requirements equivalent to first mortgage
       successful. Between our “A-paper” reputation          FICO scores that mirror less likelihood of
       and the fact that our decision makers are still       default; raising the bar for participation in the
       maturing in the low score arena, the business         program with higher FICO requirements; we
       we put on is not relatively significant yet.           determined that FICO score of 750 was the
                                                             top tier for 35% of borrowers applying and the
     - Very successful                                       low rate being the reward. Lower scores have
                                                             corresponding rates much more scrutiny, since
     - We believe that it has been succesful. We             the colleratal depreciates 1% to 3% monthly,
       underwrite based on judgement, then price the         we have refined loaning against the vaule,
       loan based on the risk it presents. What one          despite low or high credit scores!
       really has to pay attention to are young people
       having thin file A/B Credit Quality. They’ll         - We do think that we have been successful
       get ya almost every time. They don’t have the         helping members that have lower scores - we
       experience handling loss of income problems           have learned that it is important to also analyze
       that leads then to poor Credit Ratings later.         the amount of unsecured debt that the member
                                                             is carrying.
     - We do not have a “low credit score auto lend-
       ing program”. These are just common sense           - We do very little of this financing
       lending guidelines we use to reduce the risk to
       the credit union when loaning to members with       - we don’t actually go by credit score, we use
       lower credit scores.                                  debt to income ratio, low score usually has
                                                             issues that need to be addressed, we assist in
     - We do not have a formal program. We look              resolving
       at each situation on an individual basis. Most
       mainline lenders do not loan on older cars, so      - We don’t actually have a “program”, but rather
       our members appreciate the opportunity we             look for ways of making loans to as many



52   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 members as possible.                                   - We have always had auto lending for all me-
                                                          mebers, including those with low scores (or as
- We don’t have a specific low score auto lend-            we call them - on the edge), even long before
  ing program.                                            we used credit scores. We always try to work
                                                          WITH the member at all levels, and by keep-
- We don’t have a specific program for low                 ing in touch, we have been able to keep our
  credit score borrowers.                                 delinquencies down. But the most important
                                                          thing is to keep at it before it becomes too big
- we don’t proactively market it, just have it avail-     to work anything out.
  able
                                                        - We have always lent to borrowers with scores
- We experimented an increase in delinquecies             less than 600. Borrowers have an excellent
  and charge-offs this year and had to tighten            paying history.
  up on our loan policy and underwriting criteria.
  We increased financial counseling by referring         - We have been able to offer car loans...espe-
  members to our our in-house financial coun-              cially the saver’s loan..Members like this be-
  selor. We also feel that collection calls need          cause, they have savings after the car is paid
  to be done immediately (within 7 days from              off... They now know how to SAVE
  delinquent account) instead of waiting to call
  them after 30 days past due.                          - We have been able to provide member’s with
                                                          financing with rates that are considerably lower
- We find that many times the A paper quality              than they would recceive from other finance
  borrower is slow to pay more than the D or E            companies.
  paper borrower which is surprising. Members
  are so thrilled that the CU gave them an op-          - We have been successful in those that we
  portunity to borrow - they work hard at keeping         have done. However, our portfolio balance in
  their payments current.                                 the low credit score area is fairly low.

- We have a good lending program. We strive             - We have certainly seen losses in low credit
  to put the member in the car they can afford            score autos. We will not accept a low score
  and not the one they want most times. Our               new member through the indirect loan chan-
  individual credit counseling help them to be            nel.
  clear about the amount of payment they can
  afford. We also remind them that a car loan           - We have had reasonable success given the
  is more than a payment, it is several payments          economic conditions of Michigan
  (Insurance, tag/tax, gasoline,repairs etc.
                                                        - We have had record years of auto loan growth
- We have a higher charge off ratio than the oth-         to this market and have learned some things
  er auto portfolio. We are serving our mission           along the way to improve it.
  by assisting our members in auto financing.
                                                        - We have implemented the program about 6
- We have a very low delinquency/loss ratio and           months ago - it is too early to tell at this point.
  have been on risk based lending/pricing for             We have seen asset growth as a result of our
  about 5 years. Look at each case for mitigating         changes.
  factors and try to make them work.
                                                        - We have learned that notall D & E credit



                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders      53
      members are the same. We try to loan to D            - We just started our first time auto loan program
      & E members whose scores are on the way                in January, so the jury is still out.
      up and D & E members who aren’t currently
      delinquent that are trying to be responsible.        - We learned the hard way in the beginning and
      There are other D & E credit members who are           dug too deep into sub-prime. We reviewed
      just sorry with everyone. Those are the ones           policies & procedures and changed the way
      we stay away from. The only way to tell the            we were lending and is proveing to be much
      difference is to take the time and actually go         more successful now.
      through their credit report line by line.
                                                           - We partnered with a mid-prime company sev-
     - We have not had much luck with low credit             eral years ago, but discontinued last year as
       score auto loans. Harder criteria and cash            portfolio did not perform as it should have.
       down at the CU helps to insure better pay his-
       tory.                                               - We recently revised our First Time Auto Buyer
                                                             Program and added a requirement that the in-
     - We have only been doing it for a year so we do        surance premium be part of the debt to income
       not have a matured portfolio yet.                     ratio.

     - We have seen some losses higher than peer           - We specialize in auto lending and it has been
       on our portfolio, but generally the interest rate     successful. One lesson we have learned is that
       earnings offset the losses. We do look closely        whenever we’ve repossessed a vehicle and
       at their prior relationship with the Credit Union     given it back to the member, it was not the best
       and their job stability. We also offer to look at     decision.
       a good cosigner(home ownership/high credit
       score) as an option to approve financing.            - We treat our auto lending like all loan pro-
                                                             grams - we provide an opportunity - which
     - We have seen success in offering vehicle              many people in this realm (low income, low
       loans to low scored members who have an               credit score) need.
       established relationship with our Credit Union.
       In fact we do repeat business with the. We          - We use risk-based pricing . Low score doesn’t
       have learned we can build a lower risk loan           ALWAYS mean someone will default.
       with these members that we are not able to
       extend to new members especially those ac-          - We’ve been able to make a few loans to
       quired through the Indirect Channel.                  members that would otherwise have to turn
                                                             to finance companies for loans. Given the
     - We have seen that about 65% of the borrow-            economy, loans of this type are riskier. When
       ers in this program have been able to increase        prudent, we will continue to help our members
       their credit scores through an affiliation             in this fashion.

     - We haven’t pushed this program at this point.       - We’ve had no major problems so far.

     - We incorporate risk based lending at all credit     - We’ve learned the impact of lending to lower
       quality levels. Many of our members are in the        credit scores with short term employment.
       620 and below score range, so we are more
       diligent in obtaining pertinent information be-     - Yes
       fore making the loan decision.



54   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
- Yes                                                  counseling on how important it is to keep cur-
                                                       rent and pay their bills on time. Our big thing
- yes                                                  is about education for our members to teach
                                                       them how clean up their bad credit so if they
- Yes - close the loan hard at time of closing.        want to buy a brand new car or a home they
  Also we tell member that building credit with        would have a better chance with their credit
  us will help them for future needs                   score up because they have listened to what
                                                       we tried to teach them. The lesson we have
- Yes and no -- we have increased our lending          learned is that not all members listen to what
  in the underserved communities we serve --           you have to say. They just want what they
  but we have had to make modifications after           came in for.
  absorbing higher than expected losses
                                                      - Yes it has been successfully. Our credit union
- Yes and no. Having loan officers with experi-          deliquency has been less than .5% We rarely,
  ence making sub-prime loans is critical. Hav-         if ever have to actually repo a car. Although
  ing good collectors is critical. Getting involved     we have threatened to do so a number of
  with the member before they visit a dealership        times. I think its important for the credit union
  is critical.                                          to help the member make the buying decision.
                                                        Many of our members would buy more car
- Yes and No. We have grown balances and had            than they could afford if left on their own. We
  some success. It is important to have ongo-           try to educate our members and help them to
  ing training and monitoring to address issues         choose a car that is affordable after the initial
  along the way, especially when it comes to            purchase.
  non-members through the indirect channel.
  Also, be aware of economic conditions in your       - yes payroll deduction has been key to success
  area that could have an impact on your portfo-        of program. If they do not sign up for direct
  lio.                                                  deposit, loan will not be made.

- Yes because of not going too deep in the low        - yes so far.
  credit score, insurance backed, and focus on
  reasons for low score.                              - Yes, although it is still very new.

- Yes but we do know that it requires constant        - Yes, but it is a small part of our overall lending
  monitoring and immediate attention to delin-          program.
  quency.
                                                      - yes, early education and intervention is key!
- YES FOR THE MOST PART. WE HAVE
  FOUND THAT MOST OF OUR REPO’S ARE                   - yes, good tracking and monitoring is the key to
  FROM PERSONS LOSING JOB OR PLANT                      a successful program
  CLOSING. THEN WE WORK WITH THE
  MEMBER TO COME TO AN EQUITABLE                      - Yes, it has been. Imperative to ensure proper
  SOLUTION USING REPO AS A FINAL                        documentation since these loans do tend to
  MEANS.                                                have higher delinquency and charge-off ratios.

- yes I think it has been successful. We have         - Yes, it is successful but we have found that fol-
  been able to help them get their first auto with       lowing up on insurance and lien on title is very



                                   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders    55
      important.                                            Lenders Protection Insurance that helps to
                                                            insure auto loans in the 580 - 640 credit score
     - Yes, it’s been successful considering we’ve          range.
       been able to serve these lower score appli-
       cants at reasonable rates as compared to their      - Yes, We have a very good track record of
       other alternatives; all while keeping delinquen-      lending to lower credit score members while
       cies/charge-offs in-check.                            maintaining moderate loan losses. We look for
                                                             ways to make loans to our members not send
     - Yes, our low credit score auto lending program        them away.
       has been successful. We have learned over
       many years that we can take more risks with a       - Yes, we have been succesful. The key is to
       relationship member than we can with a new            evaluate each individaul on their own merit.
       member (indirect channel) who has not devel-          Let me reiterate once again that low FICO
       oped that relationship with us.                       doesn’t mean low wealth. Low FICO means
                                                             bad creditworthiness and that can happen at
     - Yes, the program has been cuccessful. A pru-          all income levels.
       dent review of the application, credit history,
       ability to repay and collateral is a must.          - yes, we have been successful using central-
                                                             ized underwriting. We understand that verfy-
     - Yes, very successful. We have learned that the        ing information on the front end is critical as
       higher the risk the better the LTV must be. We        well as speedy collections.
       push for direct deposit / payroll deduction, ac-
       ceptance of disability, gap and life insurance,     - Yes, we have transferred the risk to the con-
       and sometimes we require weekly or bi-weekly          sumer in relation to default insurance. The
       payments coinsiding with their payroll.               consumer pays the premium in relation to the
                                                             interest rate charged.
     - Yes, very successful. You need to price it high
       enough and charge enough fees to offest the         - Yes.
       losses. Also, using the credit bureau pre-
       approval model eliminated the subjectivity of       - Yes.
       having a loan officer underwrite these loans.
                                                           - Yes. Aggressive Collection Activies On delin-
     - yes, we also require an acquisition fee of            quencies.
       495.00 from dealers to reserve for loan losses.
       be sure and verify all information on credit        - Yes. Don’t focus on just losses, price for the
       apps.                                                 risk taken and the overall profitability will be
                                                             there even if losses are high.
     - Yes, we are not doing anything in specific. Our
       normal FOM is county employees. Many of             - YES. EXTRAORDINARILY STRONG COL-
       them have lower income jobs so we were use            LECTIONS DEPARTMENT AT START OF
       to meeting their needs. We only use credit            LOW CREDIT SCORE LENDING PRO-
       score of a rate. We look at the member in             GRAM.    MAINTAIN BALANCE WITHIN
       whole.                                                PORTFOLIO. 75% A & B, 25% OTHER.
                                                             REFINANCING OR WORKOUT LOANS DO
     - Yes, we have a successfull first time car buying       NOT WORK. ONLINE AUTO AUCTION
       program and we are also looking at CUNA’s             FOR REPOS MINIMIZES LOSSES.     EV-



56   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
 ERYONE HAS A GOOD STORY WHEN                           credit score low because they do not pay their
 THEY WANT SOMETHING. CONTINU-                          bills on time or is it low because of a medical
 OUSLY KEEP TRACK OF ALL POLICIES                       bill collection account? Are they requesting
 AND PROCEDURES FOR NECESSARY                           to buy a reasonable vehicle for transportation
 CHANGES.                                               or are they trying to buy a Hummer? I will not
                                                        generally loan to someone who has already
- YES. It is new, but so far it has been success-       had a repo. I look very closely to see if they
  ful.                                                  are building debt and the potential for them
                                                        to file bankruptcy. Today, I look carefully at all
- Yes. It’s an advange remaining a single seg           applicant’s mortage loans. If they have an in-
  credit union and fostering the trust and loyality     terest only loan or a negative am, I underwrite
  of our membership.                                    their loan using what their payment should be
                                                        when that loan is fully amortized.
- Yes. Members will pay for their transportation
  to their jobs. High FICO score does not guar-       - Yes. Track them carefully for delinquency
  antee members will pay for titled loans.              with unique coding and act quickly to stay in
                                                        contact. Limit your exposure to deficiency bal-
- Yes. Monitor the program closely and make             ances and tendency to walk away by requiring
  adjustments quickly. Do a good job of track-          enough money down.
  ing, analyzing and reporting to Sr. Mgmt and
  the Board of Directors.                             - Yes. We have a very low repossession rate on
                                                        low credit score loans. Using payroll deduc-
- Yes. We have learned the it is very important         tion and ACH payments along with agressive
  to set and stick to specific LTV guidelines and        early collection calls keeps delinquency to a
  other loan requirements (verification of income,       minimum.
  set up direct deposit) to reduce the risk and
  losses that may occur more often with this type     - Yes. We offer better financing rates to our
  of loan.                                              members and we have not seen any increase
                                                        in our delinquencies or charge-offs.
- Yes. We have learned when treated right, low
  score borrowers are just as apt to pay timely as    - Yes--always call if payment is 15 days late
  high score borrowers.
                                                      - Yes--some members just need a break to get
- Yes. We take a second look at loans turned            back on the right track. When we give the
  down through normal channels. We base the             change they become lifetime dedicated to the
  decision in the individual and how they have          Credit Union
  paid car loans in the past
                                                      - You have to get in touch with them, sometimes
- Yes. Building the loan correctly is a key. Buy-       at one day past due. Try to get direct deposit
  ing a vehicle that is reasonable, getting cash        or PRD.
  down, payroll deduction, and hard closing
  the loan are keys. We realize that when we
  help these type of members, they will be loyal
  forever.

- Yes. Learn from their credit history. Is their



                                    Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   57
      Notes




58   Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders
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        Steer Clear: How Credit Unions Help Car Buyers Avoid Predatory Lenders   59
             National Credit Union Foundation
601 Pennsylvania Ave. NW, Suite 600, Washington, DC 20004
        5710 Mineral Point Rd., Madison, WI 53705
              800-356-9655, extension 6772
                       www.ncuf.coop
                      www.cuaid.coop

						
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