In every business, the need to act with professionalism and integrity is critical. That seems to be even greater in a highly regulated business such as consumer finance. After all, not only are customers looking over our shoulders, but so are regulators.
The reason to “do the right thing” is certainly a moral imperative. It is also good for business. Customers know when we are acting with their best interests in mind. Of course, we are not fiduciaries for our customers, and we are in business to turn a profit. However, offering our products and services with a view to our customers’ needs and best interests is not in conflict with the best interests of our business. In actuality, what could seem like competing interests, really are harmonious.
As we examine the various laws, rules and regulations, it becomes clear that they are largely designed to produce clarity and transparency in our business transactions. When I say this, I have in mind the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Truth-in-Lending Act, the Federal Trade Commission Rules, the Gramm, Leach Bliley Privacy Act, and the Telephone Consumer Protection Act. These and the myriad of other federal rules are primarily designed to inform our customers of our loan products and services. In so doing, our job really becomes simpler because our customers know what to expect in accepting our loans.
We have learned to live under a system calling for disclosure to the “least sophisticated” consumer. That is an important standard to keep in mind. And, this is why I emphasize looking for traces of elder abuse and financial illiteracy when interacting with our customers.
All of this requires consistent training for CSRs and diligence by our compliance supervisors. But, this diligence and compliance management will serve us well in the end.
