<ul> <li>Navigating the capital markets</li> <li>The struggles and successes of private equity</li> <li>Whole loan market heating up</li> </ul> Presenter: Paul Kerwin, Executive Vice President & Chief Financial Officer, Westlake Financial [toggle title="TRANSCRIPT"] <div class="transcript-scroll-box"> 00:00 This next session is actually a new one at the conference this year. It focuses on underwriting challenges, like lengthening loan terms, with the laying down payments and stiffer competition in the subprime space. The panelists this morning didn't touch on some of those topics. But I hope in this session, we'll look at them through nonprime subclades. And so you'll be able to read so fresh insights and certainly ask any questions you have. We'll try to get to as many of those as we can. We have three seasoned executives on this panel to help us navigate the issues. To my immediate left is Burke 00:45 George, 00:46 regional Executive Director for underwriting ally, Jonathan Levin, President and Chief Executive Officer at Turner acceptance, and Terry Robinson, Senior Vice President of originations at consumer portfolio services. I'm going to start off the panel by having each of them introduce themselves. Just tell us a little bit about your responsibility of your respective organization and then I'll pick it up. 01:16 Next work Georgopoulos within Charlotte, North Carolina. My responsibilities are primarily around the consumer credit operations 01:26 at some risk functionality, but 01:29 our group is actually the 01:31 group that takes care of the dealers and looks for solutions from dealers as the end user customers, obviously for 01:44 Chicago, Illinois, 01:45 do indirect 01:46 and direct loans. We have six branches. My primary role is I have a team that I work with every day, great managers ready tequila team. So my role is just to be with them every day. Get into the weeds and see how we can deliver a great from 02:05 Terry Robinson and with CPS, which is not 12 Protective Services, consumer portfolio services, 02:14 and I miss acps. I want to clarify that up front. 02:18 Guys, I've been with CPS forever. 02:21 And I think I've done everything in the originations department from processing the funding and credit. So now I just oversee the entire department in all those areas. And I work with marketing liaison between our sales force and our credit group. And I sit on the risk committee and help decide which changes we're going to make to our programs and policies. 02:51 So we're talking about underwriting and really have an additional conversation. You know, we kind of talked about the elements that comprise That, you know, whether it's sales, credit funding, and so maybe just for each of you, you could explain a little bit about how those departments are structured and aging the things they within those departments in the past year or so, and also right. 03:17 Under originations, I have Fendi 03:22 which we used to call underwriting it. We call it funding now in credit, your credit analysts and processing and you know, credit buyers. Look at how the decisions, the approvals that declined a word with the representatives in the field, in the dealerships, negotiating structures, things like that. funding and processing of all the verifications the document review and work with the dealers in the applicants get slips in. Meanwhile, we have marketing on the other side and even Though, you know, they're two different departments, different form heads, they work very closely together. And nothing has really changed too much in originations. But we did. And I couldn't find it marketing a couple years ago, we were like, okay, we're going to change this and put sales. And then we are changing it from four years now. We've had in house marketing reps, and now we're moving app to feel about. So that's probably the biggest change that we've done in the last couple years is about changing marketing sales and 04:37 not hiring more in house and 04:40 so I was the impetus for that change and what results have you seen? Okay. 04:45 Well, I think, you know, after we started doing some skin, you know, after the recession, financially, it made more sense just to bring people in house. You could hire them for less money. But you could still cover large territory, you know, I could be working California and Texas and Pennsylvania all in one day, you know, instead of having three separate people in those territories, and we just did that for another 10 years or so. And then we just thought, well, we're not really getting anywhere. So mine was less. Let's go back to the old model, pre 2007 circuit we did so. So we changed it. And then just to give them a boost, we also created a sales support group within the marketing sales department. And so our our sales support group is made up of former in house reps and they are our lifeline to our field reps and it's it's gotten field reps off the ground much more quickly. And that's one way that you've been able to grow without cutting these breeds, buying paper, things like that. Just getting face out there 06:00 again. Excellent. Now, Jonathan, I think a lot smaller scale for Turner executives, relative to the national player the CPS is so maybe talk a little bit about how your organization is structured with regard to those departments. 06:20 I think it helps if I go back a little bit pre recession, we were predominantly an indirect monitor. And then we have branches that offer direct to consumer loans under them. While we had at the investigations department, we have the funding department, we had sales reps on screen. And then we had the buying department through the branches we just did again, like I said, direct to consumer. Post recession, competition came back really strong. There was a lot of capital that came in. We made a conscious effort to put more focus more energy into the direct to consumer loan pulled back from a lot on the end of the record just was not profitable for us to try and compete. But it was definitely advantageous for us to cater to the cost of attendance we actually passed with and that was the customers every ever books and because of our local footprint, we were able to really capture that market and some of the changes that we've made recently is because of the branch network, we don't need that all these different departments and different silos. We have as we found a great sales reps, loan officers, they all understand how to put a deal together from from inception to leading into work gets put away in the finals. So direct to consumer indirect, whether it's for auto and secure loan, retail merchant, it all flows through the branches and each branch is champion that they know Managing home. So that's the biggest change we've made. 08:06 And we are set up similar probably to the CBS organization, we've got a contract process in separate silos. Within the consumer operations here in my group, as I said, on the underwriting side, so we do interact obviously, very closely with our department, our contract Processing Center, a lot of deals route back and forth between the two to make sure that we're getting the proper validations verifications. We have an extra health safety that that's really regionally situated because they support not only the consumer originations, but also also so those those folks work very closely as metrics partners with us and they 08:54 honestly, government nationwide, all 50 states so it's very large group in the field in front of the others on really a daily basis for an underwriting standpoint with a large number of underwriters who are very, 09:09 still very high touch model 09:12 at times trying to get our underwriters on the field, we think it's important to do so that they know the process talking to the lover in the phone. So that's, 09:23 that's interesting. Has that been the case for a long time with the underwriters go out onto the field periodic video, is that something that could change? 09:30 No, it's something that we pride ourselves on dealers, dealers are very positive about on the on the show to go out and buy a field that they can get out for dealer visits with their sales partners. on a periodic basis, not not not real frequently, but depends on the student. far they are away from the market. The office with what kind of free was evident 09:53 that my goal was quarterly, 09:56 six months or six months for some Yeah, depends 10:00 on where the deals are in relation to whether they are people all across the country. So you put somebody in a local market where they have easier access. That's direct to 10:14 what are some of the broad trends that you see influencing underwriting originations, you know, over the past even just the past six months or so? 10:26 Yeah. So if you heard some of the some of the earlier sessions today, I think interesting, a lot of talk. I think affordability for the customers, there's interest rates poking up, we don't really play in the new subprime business, we probably are kind of in the very top end of the subprime getting on the lower end of time, but I think affordability is as interest rates have moved up cars have gotten more expensive. We will obviously shift in a lot into more and more use carpet. And I think that still very, we still have a lot of new car business, but finding the affordability for that customer is going to be the biggest change. And that's really driven by interest rates. 11:16 So as that becomes more of a challenge, let's say, Jonathan, how do you plan to, you know, keep originations at the level that you would want them to be? Well, 11:31 the question 11:34 is both the same. And I think the originations for us will be easy, a lot of rare opportunity to really capture growth because we believe that there was a lot of customers over the past few years that were put in financial products that didn't go up in the wrong car. payment. affordability was definitely a huge issue. For us affordability positive On the fact that I haven't worked out but that was the capacity you got you got a credit challenge customers that are buying cars that are that are one of the problems that you got companies fans and these customers that don't belong to these customers because they don't know how to manage it. So we are looking forward to the opportunity for the tightening in that world calm it's starting to calm so better than six months we're starting to see some customers come back because we're not managing well we don't have a right sizing the right car right payment and help them be successful. 12:37 negative equity and terrorism. Anybody want to just address the trends that you're seeing with regard to negative equity. And again, you know, how How much longer do you think that trend until you collect the data for the ratings and say we'll do something more dramatic to make sure that Hospitals are in the right vehicles that the right thing that's out the right codes 13:06 which says you're already having a high interest rate. 13:12 And then, you know, the little mixed up a lot of value. And so there have been negative equity as well has always been there, but I feel like it's probably going to be trending even higher because you know, a lot of lenders out there now that are guaranteed back in and then the dealers love it and they eat it up, it is just not good for the customers and you know, the beginning the dealers, our customer, but then we then the customer becomes our customer and servicing. This is quite a challenge. You know, surfacing. They missed a payment, they get an extension, three years into the loan, they can still be in the same balance as when they bought the car. Then how are they going to get out of the car You know, how are they going to do that? And, you know, I recently saw a little like that the rep called me He's like, Terry, you know that he sold $12 million in the open this loan have four years ago. Like, I 14:13 know, I looked at it with 14:14 our service Ubp. And she's, like you said an extension. I don't know how many extensions, but, I mean, it's just it's getting worse, you know, if we continue to increase the loan to value and, and require less down and just pack them into these cars. I don't know what's going to happen. So what 14:34 do you think will be the tipping point or, you know, what's going to be that trigger where you say, okay, you know, we're gonna just need to pull back whether the dealers like your customers like or they don't like it, you know, this is we just can't continue at this pace. I mean, 14:49 I think that's what's gonna happen. And Jonathan and I kind of talked to you about that in the film, and you'd have to be willing to walk away when the deal just doesn't make sense and Obviously, we don't really say this morning. No doesn't say this morning, you say no, and that means no deal or something like that the executive panel. You know, our motto is no means new offer. So it counter but I mean, it's just a struggle trying to please our customer. Knowing that we're going to have that far on our books for the next three to six years. 15:26 I think that it goes back to my comment, this is opportunity. This is where we are going to embrace that customer to have to walk away again, they were put into a long product and put into a card or put into a balance or payment. It was not set up for them to be successful. So that's an opportunity to really help customer say we're simply putting in something that was not right. So for us if there's an upside down challenge for our customer that comes back to deal a relationship. What's your relationship Are you educating the dealer to help that customer, we're in a position where because of our footprint because of our brand work, we could refer the customer back to that dealer. Hope the dealers in a position where they can be considerate of what they take the car back on trade and help them outside of that negative equity challenge. And again, it's just helping the customers to succeed. Our position, as always, is that dealerrater for one, one transaction or data for the long haul? And don't be afraid to say no, if it doesn't feel right for the customer, at the end of the day, I look at it, it's it's reputation for us. Maybe we hurt the customer. So I want to help the customer rather than lose a customer because we said no. Because we can help them so it just feels better 16:48 to have conversation directly with the customer. Is it or is it always really through the dealer 16:55 to your dealer. For 16:57 us, it's both it's It's an indirect channel is a dealer. But again, there's always that customer interview. If it's direct, they're sitting in front of one of our great loan officers that really educates the customer. And make sure again, you have the right transaction, the right thing for the right car, they don't get by. And that way they're helped put together to do. 17:21 But have you have you started to get pushback then maybe from the dealers? Or have you had to have those conversations then with the dealers, about, you know, this is where we're going to draw the line? 17:33 Yeah, there's always that push back. dealers don't like being told No, they don't like the level that they got to get more down, or they had to reduce their price. And they got basically stuck on the customer. You know, again, what are you in business for? I believe, as a logger, I'm in business to call the customer I'm not in business to put the customer in a bad transaction where they're going to fail. So try and educate the dealer. That's the business. We're in the business to help customers. So here Gotta get pushback. But there's a reason why we're still here. And we're still lending and there's a reason why others are not. And it's because of that. It's just how long can you weather that storm? How long can you sell the sidelines? And how long can you wait until another company or companies for that matter have stopped offering that product? 18:19 I think that that's right, negative equity is always going to be there and it's magnified somebody along the terminals and customers flowing a quarter trillion cycles and potentially they should, but I think ultimately, you know, when you when you set your loan to value, it's based on what the risk profile their customer 18:45 one of the issues that's out there is a rational competition, 18:48 somebody will come up with a higher 18:51 buy or with additional back end, something that that is difficult, a difficult situation with the customer. So that as Jonathan said, without we're looking to make sure that we're helping the dealer, we're taking care of the customer and the transaction that makes sense for them. 19:09 And then obviously, ultimately, 19:11 profitable transaction for ourselves. 19:15 Can you maybe describe a little bit about how the competitive landscape has really evolved in the past eight years so 19:24 yeah, I mean, there's there's a world of different competitors out there and you know, credit unions are certainly something that has come up and I think that you know, they they tend to not have as tight of restrictions sometimes on their policies, what they're willing to do, but you know, I wouldn't put it just on them aids everybody. People find what they anticipate is a little bit of a sweet spot, and they, they go all in for that they find ways to put deals together within that sweet spot. Honestly, you don't know for At least six, probably 12 to 18 months, we've made the right decision sometimes. So it's there's just a lot of competition out there, great start moving on people's balance sheets they need additional loans on. So there were activities 20:17 along those lines, you know, maybe you can talk a little bit about the process of making underwriting changes or changes to, you know, the, you know, the credit mix or terms of, you know, sort of what's involved in that process of making the change to your underwriting procedures. And then, you know, is that something that gets communicated to the dealers or is it something that they just, you know, add a word on the fly, they submitted an app and, you know, yesterday it was, it was accepted. 20:57 Some of those were very analytical We look at the data behind a lot of our decisions, we run everything through simulators models when we start to try and make a change to determine if it's something that would work benefit. So it is some of both there are some program changes that you go straight to the dealer with and you say this is this is what the new 11 is with this is where the policy is. But there are also other things probably which you can pull pricing certainly as long. If you've got a segment that you don't think is performing as well, you may be priced up and you don't get as many so certainly is a lot of levers to pull and not all of them involve the one out so now to deal with a flyer which certainly 21:51 carry 21:53 ours our process is as similar 21:56 if we if we get where 22:00 Go through the risk committee we'd would do, you know, in the status and, and try to find those pockets where we can 22:09 maybe have the opportunity to grow the business without sacrificing credit quality. 22:16 If it's if we increase prices we don't we don't 22:21 change our rate car if 22:26 we don't, we don't do a lot of changes to the programs that would warrant advertising into the dealerships. The only one I can really think of is every quarter so we may change the our preferred cars. And then you know, if we do that, then we would have to lift English now and then we rely on the sales force to get the word out for us in all the newsletters. 22:59 Jonathan has Question for you related to. Alternatively, I think, for many years, we've heard about it, but I think now it's really become a part of the underwriting process. And you know, maybe you could just discuss some of the types of data that you will find helpful for your customer base. 23:23 Well, I said that 23:25 the alternative data has been really wonderful. 23:30 components are trending follows 23:34 the thin files, Id on a big utility bills, NSF checks, automated change your cell phone often didn't change addresses, all that plays into how is the consumer ultimately going to perform. So when you take all that and you put it through the blender or through regular fica scores or any other type of credit reporting measure says it really, it helps you It tells a good story, so On our world, we brought it in, we've tested it, it's definitely helped us deliver a great product with great school great tears, and we have a better understanding of who our customers are. And that way we can again, put it in the right loan, the right car, the right bank and the right product. And you know, the risk five, so it's anybody that's a lender, I would always challenge everybody to reach out and try and learn more about how they can get alternative data to their next 24:32 sequence. 24:34 Anyone want to add anything about non traditional data or 24:40 is it just information right? So the more information you have, the better decision you can make and potentially pricing right away and capture more contracts. And, you know, there's a segment of our population but it's not like there's only people sitting in this room and it was certainly opportunities with some lows and 25:06 I'm looking at some of the questions from the audience here. And there are actually some background questions I suppose I should have asked at the outset. But for each of you, how big is there, how big is your portfolio? And then also, how do you define underwriting where it starts and where and so, Terry 25:30 Turner folio 25:34 and underwriting 25:38 I'm getting the feeling that you guys your underwriting is the credit side the decision inside and our underwriting. We find it as the document review and the verification process. So I mean, it starts in credit with you know, The dealer asking for approval getting approval on the structure for together. package comes in and we edit documents and do the verifications, send it off to a QC department as one last set of eyes to make sure. 26:19 We followed all the rules, our vendors and customers follow the rules. And then we're gonna 26:27 turn it over my friend Laurie. And 26:34 as far as size and stuff goes, I want to answer that and but as far as underwriting goes, it just it starts with the application, whether it's from the customer directly to one of our branches, or online, or from the dealer 26:51 through a whole decisioning process. And then the real real heart is in the investigations and that's when you aren't allowed because there's no For an interview involved in that, and you want to make sure that the information is accurate as the customer presented it, so 27:12 we're big 27:15 Yeah, we're gonna 27:18 take this morning's earnings announcement of $14 billion in assets and about access to 70 of that retail. So, 27:29 you know, underwriting for us do obviously take applications and run them through scorecard and our writers decision, a large percentage of the applications that come in manga do auto decision both on approvals and declines, but we have a large percentage that young writers do actually look at make credit decisions. So a lot of tools a lot of the things that they can do, they can utilize to make decision making but then once they transmit that back to the dealer or talk to the dealer on the phone preferably then the underwriter the initial underwriting piece is done. The contract comes into our processing center and a lot of times back and forth, as dealers don't always do their paperwork, right, but there are a lot of interaction back and forth. And then our, our contract Processing Center does complete development. 28:26 Just like to add just specialty financing. I've always said it's, you can't automate it. It's, you can automate pieces on it, you can automate the credit decision sandbox, but you got to allow for a review, you got to allow for that customer interaction. You got to allow make for exceptions, but you can't automate it that requires back in the days before, certain regulatory environment kicked in, I like to call a storytelling financing. Because there's a story behind the reasons as to why the customer has the credit challenges or lack of credit. It was an opportunity to learn what's the story, and then you can make a decision based on that. So now we're in positions where we can all sandbox them. But there's still a story, their sole reason of the why you should work together, why you shouldn't vote together. And you get to learn a lot more if you just make sure you infuse that into the decisions. 29:19 For you find that the manual element, or the percentage of applications that are reviewed manually is increasing or decreasing or positive. 29:33 It's really fairly flat. We're always looking for opportunities that 29:37 are made more 29:39 moves up and down sometimes we 29:44 were seeing was coming in. 29:50 So there are a couple of questions here. I think they go hand in hand how digital archiving your underwriting process and then what is your normal turnaround decisioning time. So Terry 30:03 norbury automated on 99% of our applications or automatic decision. 30:12 But, you know, most of those decisions are chemicals. So that gives the dealership the opportunity to call in and talk to a credit buyer. And that's when the credit buyer, you know, I agree with Jonathan, you can't be so automated that you lose track of what you're actually buying, you know. So it gets our buyers and our dealers and negotiate, you know, structure and things like I forgot, 30:37 you 30:38 know, how long do you think that process? Okay, well, I mean, obviously, the automatic decision takes three seconds, three seconds, yeah. 30:47 And then the like, kind of from start to finish about how long with the decisioning process, it will lead with the verifications. 30:57 Well, even when we try to track it 31:01 We allow a two week period between the time that we approve the deal and the turn the package comes in. I mean, it could be two days. It could be 31:10 longer than that. But we've always used that guideline. Once the deal is in house. 31:16 We've been running about 300 days. 31:24 quick answer to how quick for callbacks? 31:30 No, it's, 31:31 I would say that it's within a half hour timeframe. If it comes through the portal, it's sandbox. So you already know what's your falls in half hour at most to talk to the customer talk 31:42 to the dealer 31:44 from getting the deal in to booking it, where they're actually getting a payment book. You know, it could be as minimal as 31:51 half a day, depending if it's a direct call to 72 hours. 31:57 If our mindset is if work We're holding a deal for two weeks, something's something's hidden. There's a challenge. So that's probably a bad idea. 32:09 So 32:10 it really varies depending where we're seven days a week shop. So we are, it really depends Saturdays are different than the ones. But you know, somewhere in the neighborhood of 10 to 50. Decisions normally where we're at, obviously, all the funding, verifications, and things like that can lead to death. So where they they revert over your losses in some kind of 32:40 a question about terms. I think for each of you, I'm really curious to know what is your average loan term and how that has shifted? You know, again, over the past year or so, and then there is a question here related to 84 month terms are we going to flatten out at 84 months or extend further so 33:02 I'll start with the long terms. I am anti long term. I think it's bad. I think it's terrible for consumers. I know that it's dealer driven, but I think it's not something good for customers. As far as on our end, you know, our loans are not real big balances our other loan is under 39 months and our director consumer loan is under 27. 33:30 Two months is kind of become the standard term. It's probably about what our average is we we do something for months. Obviously, tighter credit locks on that a little bit more restrictive. But I don't think that they for months continues to be personal opinion. This is allies opinion, but I don't see it growing significantly from where it is. There's a law of diminishing returns and I certainly don't see it going beyond that. 33:59 Stick has an average term investor see seven and a half months. It hasn't really moved recently. It has moved out over the years. And 34:11 I mean, we would never hit 80. There's a long time that I don't think we'd ever wait for next. 34:21 We 34:22 are very consumer. 34:29 Warm earlier today we won't have all this negative challenges, 34:33 liquidation rates, just horrible industries. 34:41 I remember rolling out 60 months, that's a long time and he would look at you and go, I can't ever train somebody else 16 months along. The fact is customers do trade out. A lot of longer terms do realize they're going to come to cash if they want quicker trade cycle. So you know that Obviously, you're moving up the credit spectrum when you're doing that, but it is. It comes back to that affordability question that we started with how to get customers by vehicle, if they're not leasing the payment that works for them. And it's it's part of the challenge. 35:20 So that that kind of ties in with this question, which we've touched on, I think to some degree, but, you know, maybe some practical tips for how do you align dealers and customers interests? 35:40 I think Jerry said early on the first customer, reaction dealer customer, but ultimately you're going to wind up with that, that end consumer as your customer and you really have to balance that. I think it's critical that you do your dealer education, make sure they understand you And Porsche program rules, will dealers accountable when something bad happened that they were responsible for? and servicing is obviously a big piece of that I can share that concern drive on the servicing side. And it is a delicate balancing act. 36:20 I mean, we do have some dealers that they know, CPS, CPS forever, you know, they buy the right cars for CPS and, you know, their portfolio performs extremely well and so you know, it's nice when you can get your shit like that. But I mean, we have 8000 dealers and getting an average of two contracts per dealership. Yeah, so it's very difficult but it's nice when you have those dealerships who want to be your business partner not looking to grind every borrower and criminal Fender bro. 36:55 I would 36:56 go deal with partners definitely be positive in the portfolio. You know your dealer really well, 37:04 from the customer behavior, so if you manage if you got a lot of their complaints tell us a lot about the dealer. Our underwriting is only as good as our dealer sometimes. So we can be really good at evaluating credit risk, but at the deal or perform while they don't take good care of their customers, you've just increased the chances of increased delinquencies and not satisfied customers. So that's a great way of measuring dealers, road dealers, you got to get rid of them, you just you can't do business with them. It's great to get a customer but even the Buster customers can be ruined by a bad practice to deal with mechanical breakdown. We're financing cars that are, you know, susceptible to mechanical breakdown, how well because the dealer kind of jump in and help out and the willingness tells you they're interested in the customer. So 37:59 we have a bunch of questions that are kind of all over the board. So I'm going to try to get to as many as I can in these last few minutes. But what key credit attribute attributes do you use to place customers into tiers where they can just see the what are some of the primary attributes to look at that, you know, maybe are, 38:21 you know, something specific to your customer base very 38:27 well. 38:29 And I'm worse for bass driven a lot. But we do have certain criteria that we still use 38:39 to place the customer in the tier. It has a lot to do with 38:44 their criteria for that program and then the score range for that program. So the system will use both scoring and 38:55 characteristics. 38:56 Now homeowners will be slotted into a coal miners could be slotted into our attitude program. Back in the old days, you know, if you had a home custom program you got now you can be a homeowner and be slotted into our lower tier program. So it is mostly score driven. 39:17 I would just say score driven than the typical attributes maintain 39:24 stability. 39:26 Have any of those in recent months shown a greater influence on or comments or performance? 39:38 I think the 39:39 greatest influence is not 39:41 any one particular 39:42 attribute. It's really sticking to the guideline and sticking to that what the data tells a beautiful story. experience doing this for a living tells us even a better story and sticking to it and making sure that if You're making exceptions that make sense? Are you making an exception for the customer you make accepted for the deal? Are you making an exception because you know it's going to be successful. So just 40:12 as a question here for you. 40:17 What's the first set of applications in which you get an automated the center? 40:24 Windows Server roughly 40:30 40 to 60%. 40:33 We're always looking for ways to improve our efficiencies and stillness. 40:40 Another question about alternative data? It seems to be quite popular in the in the budget questions here, but how do you get dealers to incorporate alternative data into their process? And would that not help get more deals done for both the dealer and the lender? 40:57 So I think yes, dealers have been a little slower to adapt to alternative data. I think it'll come but you're always gonna have proprietary use other integrated, so I don't know that it's it's as simple as them starting. I think they'll use it for potentially for sales per 41:21 lead source, but I don't think it's as simple as 41:26 them taking their score and saying that's the score we should use. 41:40 Okay, we didn't really touch on this. I know we will talk about it a little bit later in the afternoon, the late afternoon panel but 41:49 fraud and misrepresentation. 41:52 Terry if you want to just address that, you know, what you're seeing is becoming more frequent and what you're doing about it. 42:01 Yeah, it's becoming more frequent because I don't know there are websites galore they'll sell you for 599 42:09 clickin Phil paste a theme statement utility bill. I mean it's crazy and at first when I first saw 42:16 this I'm sending it to council I'm like, 42:18 get this guy off and it's like we can't but now 42:21 article just circulating the entire company that's amazing. The CFPB is cracking down on these websites. So you know, back in my day, it was a cut and paste in a whiteout and it was so easy to tell. 42:35 And I'm dating myself but 42:37 now it's just super hard to tell. 42:39 Thank you know when you 42:40 do the employment verifications, that helps too and you know, we do a lot of verification so we find a lot that it I mean, it rose for Neverland reason for return packages. 42:52 Everything that she was 42:55 using used to be back in the days where we used to make the joke the dealer has a print, shop with back. So, and technology today it's so true with paychecks are they're so good. And the information verifies as a scary department. So But the trick is, is then once you start catching it, you just have to find other ways to maneuver through it and verify the information. I'm going to take it one step further, don't be afraid to turn it over to the agency's office, something that we've done really well 43:24 being a part of, you know, we're very 43:28 well connected to that office and we got them involved and it helps them spur up to when CFPB came up with this decision. I'm not taking credit for but just as present. As companies. Companies need to be proactive. If you catch it. Don't be afraid to put it in front of someone's face and saying we're catching this is bad for business. It's bad for rather, it makes us look bad. 43:59 I have Another one for you. 44:02 We're almost out of time, but just a comment or two on how the fintechs and disruptors are affecting and influencing underwriting processes. 44:17 We're doing a basic letter, and that's, that's our bread and butter. It's what we think we do best. We're obviously involved with a lot of fintechs and opportunities that are out there, always trying to take a look at whatever's in the market, what's coming out what potential opportunities are there, but, you know, ultimately, I think, you know, from our standpoint, the dealer businesses today, it's going to continue to evolve and change, but you know, we're dealing with this company, so 44:51 I'll just say that on the personal front, you know, they have something we want, they have a machine. They have something that they want and that's customer service. So, I think that there's merit to be happy. 45:07 That concludes our session. Please join me in thanking our panelists. </div> [/toggle]
