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.
Key Components & Design Considerations
We develop your fee waiver program strategy with a focus on comprehensive design:
- Eligibility Logic: Define clear rules on which fees can be waived, how often, and under which specific borrower circumstances (e.g., first-time hardship, natural disaster, military deployment).
- Waiver Types: Distinguish between discretionary one-time waivers and conditional waivers tied to borrower actions (e.g., promise-to-pay or full cure).
- Fee Prioritization: Identify and prioritize waiver-eligible fees, such as late fees, returned payment fees, and over-limit charges.
- Approval Protocols: Establish tiered approval levels based on fee amount, account age, and waiver frequency for robust control.
- System Configuration: Ensure seamless integration by properly coding waiver workflows into your servicing platform and decision tools.
Operational Levers & Tools
We build scalable and compliant waiver processes by implementing key operational tools:
- Agent Empowerment: Equip frontline teams with decision guides and scripts that balance empathy, control, and resolution.
- Robust Audit Trails: Implement system-level logs to track waiver reason codes, agent ID, and time/date for full audit transparency.
- Reporting: Develop reporting to track waiver volume, analyze impact on cure rates, and identify potential misuse.
- Compliance Reviews: Ensure compliance with UDAAP, Reg Z, and internal fair servicing principles.
Why It Matters: Value to Your Bank
Our strategic fee waiver approach helps your bank achieve critical objectives:
- Accelerate Early-Stage Cures: Eliminate small fee barriers that often prevent full payment, driving faster resolutions.
- Reduce Servicing Friction: Decrease customer complaints, especially when borrowers perceive fees as unfair.
- Boost Customer Loyalty: Improve satisfaction, particularly in hardship or retention-sensitive segments.
- Maintain Revenue Control: Use waivers as a strategic lever to enhance collections, not as a concession.
Risks & Controls
We help you minimize potential risks through built-in controls:
- Preventing Overuse: Utilize analytics and manager oversight to prevent inconsistent application or bias in waivers.
- Tracking Exceptions: Monitor repeat waiver recipients and program exceptions to maintain program integrity.
- Ensuring Consistency: Audit waiver application across all channels and agents.
How We Partner to Build It
We collaborate directly with your strategy, operations, compliance, and finance teams to build waiver programs that are both borrower-friendly and regulator-ready. We help define clear program goals (e.g., reduce recontact, improve cure rate), design precise decision trees, configure systems, and train agents. We also develop robust waiver governance structures that allow you to flex tactically without sacrificing control or compliance.
Why Spinnaker?
We’re former operators, risk leaders, and strategists in the banking industry who’ve been in your shoes. Every consultant on our team has over 10 years of real-world experience leading credit risk, collections, compliance, and analytics functions at banks and fintechs. We have managed through the last recession and the pandemic. We know what works because we've done the work. That’s why our solutions are practical, actionable, and designed to perform in the real world.
Contact us today for an exploratory conversation: Shawn.Sweeney@SpinnakerConsultingGroup.com