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Managing Risk with Your CPI Program

BY MARK HEIN

Insurance tracking and placement is a critical component of a lender’s risk management arsenal, albeit not always a very popular one.It is unpopular with credit union staff, and obviously, borrowers, who have either errantly or unfortunately been force placed. However, it’s unavoidable, right? Collateral Protection Insurance (CPI), with all of its shortcomings, has been around for decades, and it generally reduces the risk to your credit union’s lending portfolio. By tracking your auto loan portfolio and proactively communicating with your borrowers about the status of their insurance coverage, you can limit risk due to uninsured losses, at least in theory.

But as most credit unions know, some of the problems associated with CPI can be quite disruptive to their operations:

  • Ensuring regulatory compliance
  • Increased member complaints
  • Deficiency balance exposure due to high premiums and subsequent payment increases
  • An increased administrative burden due to refund activity
  • Increased collection and repossession efforts due to subsequent payment increases

Ensuring Regulatory Compliance

Lenders face a unique set of challenges as regulations surrounding lender placed insurance are changing every day. Over the last few years, the industry has evolved because of regulations and fines passed down from state insurance departments, Fannie Mae, Freddie Mac, and the Consumer Financial Protection Bureau (CFPB).

Throughout the years and the increased practice of tracking insurance, lenders have found themselves embroiled in litigation about CPI programs, arising from the practice of adding exorbitant coverage that did not directly benefit the borrower, but were, unfortunately, built into the premiums. In addition, many institutions were under the false impression that CPI should, or could be, a source for non-interest income.

Now, after hundreds of millions of dollars in penalties have been paid, the trend is to simplify the practice of tracking insurance and the coverages that accompany those programs, leaving credit unions with a huge burden to ensure their CPI providers are compliant.

Increased Member Complaints and Administrative Burden

When the premium add-on from a CPI policy causes a borrower’s monthly auto loan payment to significantly increase, there will naturally be complaints, particularly if the CPI policy was errantly false placed. Either scenario is difficult for your employees to explain to your members, and time-consuming to make all of the necessary and manual account adjustments. Unhappy members puts a strain on your relationship, and in this day and age of intense competition in the financial services industry, an unhappy member could soon be a former member.

Deficiency Balance Exposure and Increased Collection and Repossession Efforts

In the worst of cases, a borrower can be pushed into delinquency because of a premium add on. By raising a borrower’s monthly loan payment to cover the cost of an annual CPI premium, some borrowers are forced into voluntary repossessions because they can’t afford the inflated price, leaving your credit union susceptible to charge offs and loan losses. As deficiency balances and delinquencies rise, collections workflow increases and cash flow is impacted. Delinquency and repossession as a result of CPI premiums are a lose-lose for everyone involved.

Evaluate Your Provider

Collateral protection insurance in general may be unavoidable; however the quality of your provider is in your control. Whether you’re in the market for a new CPI provider, or just want to conduct a high-level due diligence of your current provider, here are a couple of questions you can consider:


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