Page 106 - CARS Standard Program

who may be driving the collateral. The following procedure is suggested to be used to determine if the debtor is still employed at the given POE:
A. The Recovery Agent should first approach the POE in an effort to observe the collateral. If the collateral is not observed, the Recovery Agent should contact the POE (preferably by phone) and ask to speak to the debtor.
Example: “Hi, this is Brad Davis. May I speak to Dave Smith (debtor)?”
B. If the Recovery Agent is advised by the POE Human Resources Department that the debtor is no longer employed there, the Recovery Agent should state that he is attempting to obtain a residence or POE address and ask for assistance.
Example: “Thank you, I’m trying to verify Dave’s home address, can you help me?” Can you tell me where he is working now?” “Can you tell me how I might contact a relative?” “Is there anyone there that worked with Dave that I could speak to?” Again, the Recovery Agent should use caution not to divulge any NPPI.
Contact Procedure (Other than debtor)
When making contact (in person or by telephone), the Recovery Agent must not disclose any Non-Public Personal information (NPPI) about the debtor. Divulging NPPI (Social Security number, credit card numbers, non-published phone number, medical information, etc.) is a direct violation of the federal Gramm, Leach, Bliley Act (GLBA), which can have devastating and very expensive consequences to the Recovery Agent, the Recovery Agency owner, the creditor and the insurance carrier. The GLBA is discussed in more detail in this manual under Section 1, Applicable Federal Law. The following examples are suggested when questioning a third party:
A. “I am trying to verify the address of Mr. Smith (or co-signer). Can you help me?”
B. “Can you tell me if Mr. Smith (or co-signer) is still employed at (name of POE)?”
C. “Do you know who currently lives at (debtor’s or co-signer’s) address?”
D. “When was the last time (and location) you saw Mr. Smith (or co-signer)?”
E. “Do you remember what Mr. Smith (or co-signer) was driving the last time you saw him?”
F. “I think one of the vehicles he drives is a red Chevrolet Blazer. Have you seen that vehicle? When? Where?”
G. “Would you happen to know any of Mr. Smith’s (or co-signers) friends, relatives, co-workers, former co-workers, etc. who might be able to provide me with Mr. Smith’s (or co-signer’s) current address or employer?”
H. “Is there an emergency number where Mr. Smith (or co-signer) can be reached?”
Note: Always phrase inquires in a way that asks for help. It is inherent in most people to respond positively when they are asked for help.