Jim Peters

Proactive Compliance in a Recessionary Environment Regulatory expectations don’t pause during a downturn—if anything, they intensify. As financial institutions respond to economic stress with fee waivers, forbearances, restructures, and collections escalations, regulators pay close attention to how borrowers are treated, how decisions are made, and how fairly those decisions are applied.

Credit conditions are tightening. Borrower risk signals are shifting, and vulnerabilities hidden during stimulus years are surfacing. As delinquencies rise, banks that proactively reassess credit risk and portfolio strategy before losses accelerate will navigate this downturn successfully.

You're likely already seeing the pressure building: loan delinquencies creeping up, call center queues running long, and backlogs in workout processing. These aren't isolated operational issues; they're leading indicators of a system that's stretched and vulnerable as we head into a more challenging economic environment. In a recession, a strong strategy alone isn't enough. Execution is everything. That's why we help banks design Operational Readiness Plans. These plans ensure your teams, systems, and servicing infrastructure can perform under pressure—without sacrificing customer experience, compliance, or control.

We help you design and implement effective loan reage programs that support borrower rehabilitation, improve loan performance, and rigorously maintain regulatory compliance. Our approach transforms distressed accounts into performing assets, preserving long-term portfolio value.

How We Help You Design and Operationalize Collections Fee Waiver Strategies We help banks design and operationalize intelligent fee waiver programs as part of their loss mitigation strategy. Our approach builds structured, policy-driven strategies that improve collections outcomes, enhance customer goodwill, and reduce complaints—all while maintaining critical compliance and revenue guardrails.

Payment Deferral Programs: Building Smart, Flexible Options We help you design and deploy effective payment deferral programs that reduce near-term delinquency, genuinely support borrowers through hardship, and preserve long-term portfolio health.

Protecting Your Portfolio: Strategic Loan Modification Programs We create robust loan modification frameworks that provide sustainable workout options for borrowers while rigorously protecting your portfolio's performance and regulatory posture.

We help you develop highly effective settlement programs that recover value from severely delinquent accounts. Our approach prioritizes compliance, avoids reputational risk, and directly aligns with your overarching collections strategy.

Clear, Actionable Coding Promotes Fair Treatment in Hardship We help you implement consistent, auditable hardship codes across all products and servicing channels. This lays the essential foundation for fair borrower treatment, robust regulatory compliance, and invaluable portfolio-level insights.

Maximize Past-Due Borrower Contact Through the Right Channel Mix We help you design and execute intelligent outreach strategies that seamlessly blend voice, SMS, email, and self-service. Our approach is compliant and cost-effective, meeting borrowers where they are and significantly increasing resolution rates.

How We Help You Design Clear, Effective, and Compliant Agent Guidance We develop call scripts and playbooks that support agents with clear decision-making paths, consistent messaging, and the right blend of empathy, resolution, and control.

Partnering to Scale Collections Intelligently, Sustainably, and Responsibly In an economic downturn, Collections becomes the tip of the spear in consumer lending. But greater contact intensity doesn’t automatically translate to higher collections. Blanket strategies can backfire with regulators and borrowers alike, especially with Regulation F now in play since the last recession. Banks need to be particularly buttoned up when it comes to contact and collections strategies. This is critical for regional and community banks as they begin hitting thresholds where regulatory scrutiny increases. Agility is paramount when navigating the dynamic landscape of changing regulations. That’s why Spinnaker’s approach to collections and loss mitigation is deeply data-informed, compliance-aware, and built in partnership with your team. We deliver customized solutions that build upon your existing strategies and infrastructure. Our plans are responsive to real-world volume surges, evolving regulatory expectations, and the human side of financial hardship. Since the last recession, not only have we added Reg F to the FDCPA at the federal level, but we're also witnessing a significant shift towards more state-specific regulatory environments, requiring larger banks to navigate 50+ sets of rules based on their customer base.

Is Your Bank Ready for What’s Next? Executive Summary You already see the warning signs. Economic uncertainty is rising, credit conditions are tightening, and consumer financial stress is building. As a banking leader, you know a recession—or something close to it—is imminent. What matters now is how well your institution is positioned to respond with speed, confidence, and control. That’s where we come in. We work with banks like yours to build custom Recession Playbooks that translate strategic foresight into tactical readiness across risk, operations, and compliance. JPMorgan increased their recession likelihood forecast this year from 35% to 45%. Now is the time for banks to be proactive by developing a modern, data-driven recession playbook tailored to today’s landscape.