Peach is honored to accept this year’s FinTech Breakthrough Award for Banking-as-a-Service Innovation.

In its 7th year, the annual FinTech Breakthrough Awards aims to recognize the breakthrough companies and products in the global financial services and technology industry. Peach receives its award alongside other leading-edge companies including American Express, Ramp and Credit Karma. Over 4,000 nominations were received. 

From our [Adaptive Core™](https://www.peachfinance.com/platform/adaptive-core) to our [Self-Service Portfolio Migration](https://www.peachfinance.com/migrate), we’re proud of the innovations that are helping every lender to innovate—and we’re grateful for this recognition from FinTech Breakthrough.

For more information, read [the full press release](https://www.prweb.com/releases/global_fintech_innovators_recognized_in_seventh_annual_fintech_breakthrough_awards_program/prweb19242066.htm).


Peach receives 2023 FinTech Breakthrough Award

One look at the [running tally of CFPB enforcement actions](https://www.consumerfinance.gov/enforcement/actions/) is enough to inspire a healthy respect for the importance of lending compliance—especially as the steepest penalties [swell into the billions of dollars](https://www.consumerfinance.gov/about-us/newsroom/cfpb-orders-wells-fargo-to-pay-37-billion-for-widespread-mismanagement-of-auto-loans-mortgages-and-deposit-accounts/).

But for lenders, compliance isn’t just a checklist of straightforward decisions. The inflexibility of legacy lending technology can make it difficult or impossible for lenders to fully comply with certain regulations. For example, one regulation that frequently poses challenges for lenders is the Servicemembers Civil Relief Act (SCRA), which entitles active-duty servicemembers to an interest rate cap of 6% during the period of their deployment. This interest rate cap can be requested retroactively, which presents a challenge: Most loan management systems are not capable of making retroactive changes at scale. As a result, many lenders are forced to approximate the interest benefit through service credits, exposing themselves to risk due to improper implementation. Lenders likewise face difficulty complying with the Fair Debt Collection Practices Act (FDCPA), among other regulations.

Peach was founded in large part because of the opportunity to improve upon the shortcomings of legacy lending infrastructure—including on the compliance front. Peach was designed from the beginning to accommodate all the regulatory requirements of lending as a routine part of daily operations. That’s why you’ll find a number of features, like [Loan Replay™](https://www.peachfinance.com/platform/adaptive-core#loan-replay), that are uniquely designed to address widely acknowledged pain points such as retroactive changes and portfolio migrations. 

[Compliance Guard™](https://www.peachfinance.com/platform/compliance-guard) is the name of our compliance-focused platform module. Its functionality can be divided into two parts. First, our Compliance Guard Monitoring module scans for borrower status changes with compliance ramifications, like military status, reassigned numbers and bankruptcy. Second, our Compliance Guard Rules module scans outbound communications based on predefined (yet fully customizable) rules to ensure compliance with regulations like the U.S. Bankruptcy Code and [Reg. F](https://www.peachfinance.com/blog/how-peach-helps-lenders-comply-with-regulation-f). We’ll take a detailed look at borrower status monitoring first.

## Compliance Guard Monitoring

Peach is continually running processes to check relevant borrower statuses. For example, if a borrower is found to be bankrupt, sanctioned, deceased or on active duty, our system will automatically create a case for that person, which a lender’s agents can then review and take action on. Similarly, we monitor the Reassigned Numbers Database to determine whether borrowers’ phone numbers have changed, which helps ensure compliant communications. We also check for borrowers who live in areas declared by FEMA to be natural disaster zones, although there is no law requiring lenders to take proactive action in this scenario.

All our borrower status monitoring systems are automated. Once turned on for a lender, we will continually monitor for all relevant borrower statuses. All that’s required of the lender is to handle the incoming cases created by Peach’s system.

Our system is built to standardize the information lenders see, even though the sources of this information are far from uniform. This helps lenders to be able to focus on their core business. Lenders can always choose which types of monitoring they want—so if they don't want to conduct proactive SCRA monitoring, for example, they can choose to forgo it. 

#### Monitoring for bankruptcy and deceased

We’re continually monitoring for borrowers who file for bankruptcy or pass away. Each time we receive a hit, we create a servicing case in the lender’s CRM for their agents to review. The case contains the match level for the hit—for example, the SSN, name and address could each match completely, partially or not at all. The case also contains additional metadata about the hit. For example, a bankruptcy case will show the court case filed date, the court case number, the bankruptcy chapter and the last status of the court case, among other data. A complete list of the fields we include for each case type can be found in our [API documentation](https://docs.peach.finance/tag/Cases#operation/peach.cases.handlers.case.cases_get_by_company!c=200\&path=data/0/courtCaseFiledDate\&t=response).

After a servicing case is generated, a lender’s agents can then leverage the flexibility of the Peach platform to perform a variety of actions, including triggering communications, setting do-not-interact rules, offering hardship solutions, waiving past fees, backdating payments and more. In the case of bankruptcy, because court cases can go on for months, our system will also continue to monitor progress, updating our internal data as the court case progresses. 

#### OFAC monitoring

The U.S. Office of Foreign Assets Control (OFAC) is responsible for enforcing economic and trade sanctions. Lenders must periodically check to ensure they are not doing business with any borrowers who appear on a sanctions list.

Peach automatically searches the sanctions lists for every borrower on our platform. If we receive a hit, we’ll create a case in the lender’s CRM for their agents to review and take action on. We do this periodically so that lenders do not have to play an active role in the monitoring—they only need to handle the cases as they come in.

#### SCRA monitoring

The SCRA gives certain rights to borrowers who are on active military duty. So multiple times per week, we monitor for borrowers whose military status has changed, creating a case for each borrower. Agents can easily take appropriate action on SCRA cases, like lowering interest rates as of the current date or any past date—and waiving past fees, as necessary. For more detail, check out our [SCRA compliance article](https://www.peachfinance.com/blog/how-peach-powers-scra-compliance).

#### Reassigned Numbers Database

Occasionally, the phone number on file for a borrower is reassigned to a new person, who by definition has not given permission to be contacted. If lenders are not aware of these reassigned numbers, they take on compliance risk. For that reason, we monitor the Reassigned Numbers Database for any numbers that have been reassigned or disconnected. We then update the contact object in our system with details, and we prevent further communication until consent is received again.

#### FEMA disasters

Even though it is not required by law, Peach tracks the occurrence of natural disasters so that lenders can provide leniency based on geographic location. We periodically pull FEMA’s list of declared disasters and identify any borrowers located within the bounds of those disasters, using the geographic coordinates of their addresses. We create a supercase for each disaster, which, unlike a normal case, applies to a group of borrowers. Once a supercase is created, the lender can decide whether they want to take action. If they do, they can automatically create individual cases for each borrower in the population.

## Compliance Guard Rules

Lawmakers at various levels of government have enacted regulations affecting how lenders can communicate with borrowers. Many of these laws overlap at the city, state and federal levels, and may vary by asset class—creating a complex patchwork of requirements. Tracking which laws affect which borrowers is complicated, but Peach has created a straightforward process to help lenders stay compliant in their communications.

Whenever an outbound communication is sent, whether automatically or manually, our system loads all rules that apply to the borrower based on where they live—and runs each rule to make sure that the communication is compliant. 
![{{ w: 620 }}](/blog/Compliance-Guard-blog-post-flow%20chart.jpg)
Alternatively, we expose an endpoint that allows a lender to check if they can interact with a given borrower without having to actually send a communication. 

For example, a lender might send the following to the [can\_interact](https://docs.peach.finance/tag/Can-Interact#operation/peach.people.handlers.can_interact) endpoint to see if they can make a debt collections call to the borrower:

```
{
  "loanId": "LN-ABCD-EFGH",
  "channel": "voice",
  "theme": "opsCollDebt",
  "isAutodialed": false,
  "contactId": "CT-ABCD-EFGH",
}
```

If the call is allowed, the response from Peach would be:

```
{
  "status": 200,
  "data": {
	"result": true
  }
}
```

We continually scan for new legislation, and code any new or modified laws into our rules engine. By default, we code rules derived directly from law text into our Rules Engine. We also have the flexibility to customize the set of rules for any given lender. If they have special circumstances that require a different subset of rules to follow, or if they want to enforce more stringent rules than are required by law, we can easily alter the set of rules that is applied to their communications, or even add custom ones. This can all be edited on the platform in real time without having to release a new update of our system.

The rules are separated into business rules, federal rules and state rules, which can be further split up by city. This means we can have custom rules that apply to everyone, just to a particular state or just to a particular city. The rules are also specific to asset class, type of origination license and servicing entity, giving lenders with multiple lending programs a high degree of flexibility.

–

Though the complexity of lending compliance is likely to increase over time, many of the compliance challenges lenders face today can be reduced or eliminated with more flexible servicing technology. If you’d like to learn more about how we can help you handle compliance in the context of your specific lending program, [please contact us](https://www.peachfinance.com/contact).


How Peach helps lenders stay compliant

Tony Zerucha of Fintech Nexus News recently sat down with Peach CEO Eddie Oistacher to discuss Peach’s industry-first [Self-Service Portfolio Migration™](https://www.peachfinance.com/migrate) capability.

Why is it such a game-changer? One reason is that Peach recreates full loan histories from a small subset of data, which means far less data to gather and migrate. Another reason is that  lenders use the same API endpoints for migration that they’ll use to board new loans to Peach, enabling them to self-migrate with very little additional training. Plus, there’s no migration fee.

Check out the article to read more about how we simplify migrations, how we help lenders balance self-service with agent assistance, and what we’re excited about in the coming year.

[Read the full article here.](https://news.fintechnexus.com/peach-finance-goes-back-to-basics-to-simplify-migrations/)


Peach simplifies portfolio migrations

Peach CEO and Co-Founder Eddie Oistacher joined Peter Renton on the Fintech One-on-One podcast to chat about Peach's founding story, the biggest challenges lenders face today, and how Peach helps lenders meet borrowers halfway during a downturn.

They also discussed how Peach's Self-Service Portfolio Migration capability is changing the game for lenders who want to modernize their servicing technology.

[Listen to the podcast](https://news.fintechnexus.com/podcast-409-eddie-oistacher-of-peach-finance/)


Peach CEO Eddie Oistacher Joins Fintech One-on-One Podcast

Regulatory compliance has a place near the top of every lender’s priority list. But that doesn’t mean compliance is straightforward, even for lenders with the most earnest intentions. Often, legacy infrastructure is the culprit, making it difficult for lenders to take the actions clearly outlined in the law. Even regulations that haven’t changed for some time—like the **Servicemembers Civil Relief Act (SCRA)**—still present significant challenges for many lenders. 

The SCRA grants active-duty service members the ability to request certain [protections](https://www.consumerfinance.gov/consumer-tools/educator-tools/servicemembers/the-servicemembers-civil-relief-act-scra/#:~:text=The%20SCRA%20is%20a%20law,defense%20needs%20of%20the%20Nation) during the period of their deployment, enabling them to devote their energy to serving the country. These protections include a reduction in interest rate to a maximum of six percent on any pre-service loans. While the SCRA in its current version has been law since 2003, the number of recent enforcement actions indicates just how difficult it is for many lenders to comply with the SCRA’s interest rate protections.

For example, in October of 2022 the Department of Justice (DOJ) announced that the financial leasing arm of GM agreed to pay over $3.5 million to resolve allegations in relation to [SCRA violations](https://www.fox34.com/2022/10/05/gm-financial-pay-over-35-million-resolve-servicemembers-civil-relief-act-claims/) on thousands of service-member requests. Also in October, the DOJ announced a [settlement](https://www.consumerfinancemonitor.com/2022/10/04/doj-settles-scra-interest-rate-action-against-auto-finance-company/) with Westlake Financial, which failed to appropriately apply the interest rate reduction for service members. Meanwhile, the CFPB issued [recent guidance](https://files.consumerfinance.gov/f/documents/cfpb_servicemembers-usage-of-scra-credit-protections\_2022.pdf) signaling that underapplication of SCRA benefits is on their radar.

**Blunt tools in the absence of a scalpel**

The recent DOJ actions illustrate the high cost of non-compliance with the SCRA. In light of this cost, why do so many lenders still struggle with compliance? The answer primarily involves the limitations of legacy loan management systems—specifically, their inability to make retroactive changes to loans. To understand the significance of this limitation, let’s take a closer look at the details of the SCRA’s interest rate protection.

The SCRA [states](https://www.consumerfinance.gov/consumer-tools/educator-tools/servicemembers/the-servicemembers-civil-relief-act-scra/) that “...if you took out an automobile, home, or student loan or incurred credit card debt prior to becoming a service member, then you are entitled to have your interest rate reduced to a maximum of 6 percent per year…for the entire time you are serving on active duty.” This protection stipulates that the rate reduction can be requested at any time during active duty and up to 180 days after active duty ends. So lenders must be prepared to *retroactively* instate a lower interest rate, effective as of some date in the past. 

This modification of loan state is one of the biggest challenges for loan management software. Some loan management systems date back decades, and were designed for a much simpler set of possible actions. Even newer loan management systems may not account for the need to modify past events—because of significantly increased complexity. Loan management systems often start their life as single-use-case systems, with the aim of getting their core functionalities off the ground. But by the time these systems interact with real-life borrowers and regulations, enabling retroactive changes becomes nearly impossible.

As a result, many lenders must resort to costly, time-consuming and imprecise manual workarounds to comply with the SCRA. They may manually calculate the overpayments of past interest, then issue service credits—and zero out the interest rate going forward. Or they may resort to waiving the interest on an SCRA loan entirely—past and future. Further, many lenders have no way of reinstating interest once active duty ends. Needless to say, many lenders are stuck with clunky, costly solutions that in some cases may not even fully comply with the SCRA.

**Peach’s approach to SCRA**

At Peach, we brought real-life lending experience to the design of our platform. So from day one, we recognized the importance of being able to make retroactive changes to loans. (There are numerous applications beyond SCRA, including our [Self-Service Portfolio Migration](https://www.peachfinance.com/migrate).) In the case of SCRA, Peach has long enabled lenders to retroactively change interest rates and waive past fees—as separate, manual actions. 

This was functional, but the ideal way to implement SCRA is to make these changes simultaneously. We now support this capability by leveraging the power of Peach's [Loan Replay™](https://www.peachfinance.com/platform/adaptive-core#loan-replay) engine, which can make changes to the ledger at any time, and then recalculate a loan’s history in light of those changes. The new combined functionality is as user-friendly for your agents as processing a payment. 

Specifically, the new SCRA feature allows your agents to perform the following adjustments simultaneously on a loan of an active-duty service member: 

1.  Lower interest rates to 6% (*and* lower the recurring payment during the active-duty period to account for the interest rate reduction)

2.  Waive fees, if necessary

3.  Enact these changes retroactively, if necessary, and replay the loan history with the rate and fee adjustments 

4.  Preview the intended changes 

While each of these SCRA adjustments are highly complex in themselves, involving detailed changes to loan state and financial state, ease of use is paramount. Our SCRA API endpoint allows the agent and borrower to see the combined result of simultaneously performing two replay actions (interest reduction and fee waiving) on the same loan and payment plan. In addition, we’ll automatically lower the recurring payment during the active duty period to account for the interest rate reduction. Our tool can then be used to reinstate the borrower’s previous interest rate once active duty ends.

Our SCRA functionality is available via API as well as through our white-label agent tool. The white-label agent interface can be seen here:
![{{ w: 520 }}](https://www.peachfinance.com/blog/scra/SCRA-change-terms.png)

For those working directly with the API, this can be as simple as sending the following request body to the SCRA endpoint:
![](https://www.peachfinance.com/blog/scra/SCRA-snippet-1\_2.jpg)
You’ll receive a response with either the actual post-SCRA adjusted payment plan or a preview of it. Below is a comparison of a payment plan prior to the SCRA adjustment, and the expected payments after the SCRA adjustment. The SCRA period is in effect for the first two months, and thus you will see the interest rates lowered to 6% in the response body (*and* the recurring amount due lowered by the amount of the interest rate reduction for the two relevant months). The origination fee has also been canceled.

**Original payment plan (first 3 payment periods)**
![](https://www.peachfinance.com/blog/scra/SCRA-snippet-2.jpg)
**Adjusted payment plan (first 3 payment periods)**
![](https://www.peachfinance.com/blog/scra/SCRA-snippet-3.jpg)
(\*Certain fields omitted for brevity)

In addition to streamlining manual compliance with SCRA, Peach enables you to proactively offer the SCRA benefit to eligible borrowers. This is possible thanks to [Compliance Guard™](https://www.peachfinance.com/platform/compliance-guard), which automatically monitors for borrower status changes. We can alert you when borrowers receive orders to active-duty service, and again when active duty ends. You can then proactively reduce the borrower’s interest rate to 6% for the exact duration of their deployment, without the borrower ever needing to contact you. As the CFPB eyes [underutilization of SCRA benefits](https://files.consumerfinance.gov/f/documents/cfpb_servicemembers-usage-of-scra-credit-protections\_2022.pdf), this capability may evolve from a nice-to-have to a requirement.

Combining these subtle yet highly complex changes into a single, user-friendly tool is in line with our standard approach to feature work: building loan servicing solutions that are configurable, scalable, compliant and user-friendly.

**Loan Replay: Programmatically managing retroactive changes**

Peach’s Loan Replay capability is the engine that powers complex features requiring retroactive changes to loans. Here, we spend a little time—using SCRA as a use case—to examine the technical underpinnings of Loan Replay, and the intricate lending mechanics that make it necessary.

At their core, loan management systems act as highly complex state machines holding data for each individual loan. Lenders rely on these state machines first and foremost to accurately record and track a constantly evolving set of information constituting a loan’s state, and to ensure each change cascades correctly to update the rest of the loan’s state.

In a simplified world, the past is the past, and any event causing a change in loan state—payments, interest accrual, charge-offs, etc.—results in a permanent state transition. But in reality, there are myriad changes that can impact a loan’s history—whether it’s reversing a payment previously marked as successful, reversing a previous charge-off, or, in the case of SCRA, lowering an interest rate effective as of a past date. 

Let’s say we have a simple installment loan that was originated on January 1, 2023 with the following terms:
![](https://www.peachfinance.com/blog/scra/SCRA-snippet-4.jpg)
Because there are many stakeholders consuming information about a loan throughout its life—business, operations, finance, accounting, payment processors, credit bureaus and investors, to name a few—a single loan requires that a host of data points be recorded with precision. This includes, but is not limited to, borrower data, financial data, accounting data and payment data.

What’s more, these data points need to be represented in highly specific ways. Where operations may need only a high-level view of the numbers, finance will ultimately need the nitty gritty story of a loan told in accounting debits and credits. Data analysts and credit bureaus require tracking of delinquency in specified ways, while borrowers only want to know whether they are current or overdue. It becomes clear that any event impacting a loan requires deterministic updates across a large surface area. 

Moreover, a key characteristic of loan management is tight coupling. Firstly, we see this between various facets of a loan. Taking the example above, let’s say the borrower makes a payment several days into the loan. That single action will lead to a cascade of changes, including generating new transaction data, generating accounting entries to deplete various receivables buckets, recalculating the interest and principal splits on the borrower’s payment plan, and updating whether the loan is current or overdue.
![](https://www.peachfinance.com/blog/scra/SCRA-independent-objects.jpg)
Secondly, we see tight coupling between each successive event in the life of a loan. A payment event in the first period will impact the amount of interest that will be subsequently accrued on a daily basis (as the principal balance has been lowered), which impacts the amount of interest, fees, and principal receivables to be moved on the due date. Put simply, the state of a loan at any given time depends on the entire history of inputs—not just the most recent one. This means that the history of a loan—when payments were made or not made, when interest rates changed, when fees were booked, etc.—is an interconnected chain of events. One change not only immediately impacts the loan, but adding, removing or changing one piece means changing everything about a loan’s state from that adjustment onward.

In the example above, let’s say that 80 days into the loan, after two payments were made, the customer requests an SCRA relaxation effective as of 10 days into the loan. How do we update this loan appropriately?
![](https://www.peachfinance.com/blog/scra/SCRA-snippet-5\_2.jpg)
If the interest rate has to be lowered as of day 10 of the loan, then everything that happened subsequently will be subject to change. The daily interest accruals from the tenth day onward will change, and the first payment will now waterfall different amounts of interest, fees and principal. Depending on the amounts of the payments, a loan that was overdue may now be current, given the lowered interest rate. 

Loan Replay™ was built for use cases such as this. Broadly speaking, our architecture is built to keep detailed track of all mutable and interdependent events in the life of a loan, so that when any change is made to that event timeline or loan state, we can rewind to the time of the event in question, rewind the loan state, and create a new timeline in light of that change. In the case of SCRA, after handling interest rate changes and fee cancellations we reverse the state of the loan to the appropriate point in time, then replay the loan, recalculating the payment plan, re-accruing interest, re-applying payments and re-moving balances in light of the new reality, so that the present receives a new loan state.
![](https://www.peachfinance.com/blog/scra/SCRA-Loan-Replay-timeline.jpg)
The breadth of loan data needing to be adjusted means that rewriting loan histories requires the right design and abstractions, and having a built-in layer of abstraction to handle retroactive changes is the only feasible approach. Because of our team’s combined experience in the real world of lending, we know that the need to edit past loan events is inevitable. So we’ve designed a system that makes these changes as painless and automated as possible. 

–

Though lending infrastructure is complex, lenders must find ways to balance regulatory compliance with innovation toward growth. Peach is designed to give you the best of both worlds. [Contact us](https://www.peachfinance.com/contact) to learn more.


How Peach powers SCRA compliance

OAKLAND, CA / ACCESSWIRE / December 13, 2022 / Peach Finance, the leading API-first loan management and servicing technology platform, today announced the release of its Self-Service Portfolio Migration™ tool.

A first of its kind in the lending industry, the tool streamlines the migration process and gives lenders the ability to manage migrations themselves, reducing the time, effort, risk, and cost associated with migrating their existing lending portfolio. The tool is suitable for both installment loans and lines of credit, and is offered at no cost to lenders migrating their portfolio onto Peach's platform.

[READ THE FULL PRESS RELEASE.](https://www.accesswire.com/731522/Lending-Technology-Platform-Peach-Finance-Announces-Launch-of-Self-Service-Portfolio-MigrationTM-Tool)


Peach Announces Launch of Self-Service Portfolio Migration™ Tool

OAKLAND, Calif.--(BUSINESS WIRE)--Peach Finance, the leading modern loan management and servicing technology platform, today announced that it has joined the[ Mastercard Engage Partner Network](https://www.mastercard.us/engage/#/en/home) as a fintech enabler to help bring consumers more payments choices. The partnership is currently focused on supporting lenders in developing buy now, pay later (BNPL) solutions leveraging the Mastercard Installments program. 

BNPL is growing rapidly, with a projected e-commerce transaction value of $7.2T by 2025. But one of the barriers to growth in the space has been the challenge of merchant acceptance—BNPL providers must build merchant acceptance relationships one by one. Mastercard has helped solve this problem by developing a BNPL solution that’s available everywhere Mastercard is accepted.

[READ THE FULL PRESS RELEASE.](https://www.businesswire.com/news/home/20221207005290/en/Peach-Finance-Joins-Mastercard-Engage-Partner-Network-to-Help-Lenders-Develop-Installments-Solutions)


Peach joins Mastercard Engage Partner Network

Since 2008, the Future Digital Awards from Juniper Research have recognized outstanding organizations that are positioned to make a significant impact in the future. The Awards honor companies whose imaginative products or services have the potential to disrupt their ecosystems and provide significant benefits to their target audience. 

Peach is honored to accept this year’s Gold award in Banking-as-a-Service Innovation for our cloud-native lending technology platform. From our Adaptive Core™ to Compliance Guard™ to end-to-end servicing tech, we’re proud to continue building toward our mission of improving lives by giving every lender the power to innovate.

[Read the full press release.](https://www.businesswire.com/news/home/20221010005608/en/Juniper-Research-Future-Digital-Award-Winners-Announced-for-Fintech-Payments-2022)


Peach selected as Future Digital Awards Gold Winner

First-party collections capabilities are a crucial component of any lender’s toolkit—especially in a market downturn. They enable lenders to retain 100% of what they collect, and they empower lenders to control the tone of customer correspondence, giving them a chance to preserve borrower relationships.

To be effective in the context of ever-improving customer experiences, collections strategies must be tailored to the needs of the borrower. That’s why we’ve created a borrower portal that maximizes borrowers’ ability to self-service. It’s also why we created the first lending platform with native first-party collections tech built on top of an enterprise-grade loan management system. This means that when borrower self-service isn't enough, agents are empowered to truly help customers through automation, intelligence and powerful loan modification tools.

Here are three ways our collections capabilities can help you master first-party collections and achieve better outcomes from your delinquent accounts. 

### 1. Repayment engine

Our proprietary, lending-specific CRM is configurable on a roles and permissions basis, so it can accommodate both in-house agents and third-party BPO access. Here’s an overview of its capabilities.

**Loan modifications**

With Peach, your agents get access to a full set of loan modification tools, enabling them to meet customers halfway with flexible payment options. Agents can manage payments and hardship and modify receivables—for example, waiving fees, issuing credits, deferring due dates, changing or extending terms, creating payment plans, reversing payments, backdating payments, and more. We support unique products and policies by geography.

**Cases and workflows**

We provide out-of-the-box cases and workflows for collections-related servicing scenarios like bankruptcies and disputes. We’ve also made it easy to create custom cases and workflows so you can design them around your own needs.

**Communications**

We provide pre-integrated communications tools for phone, email, SMS, two-way texting, chat and physical letters—ready to use in automated or manual fashion. We give you out-of-the-box templates for white-label emails, SMS and letters, and you can add your own templates, too. 

You can also set automated, no-touch rules to help prevent accounts from going to collections in the first place. Automatically send custom communications or leverage our templated reminders to create an account, enable autopay, make an upcoming payment and more. You can also configure rules for recovering debts, leveraging templates on the cadence and via the medium of your choosing. 

**Compliance monitoring**

With Compliance Guard™, we’ve coded the federal and state rules governing collections communications, including FDCPA, TCPA, UDAAP, SCRA, the US Bankruptcy Code and applicable state analogs. Every outbound collections communication is run through and approved by the rules engine, and our system automatically blocks non-compliant communication attempts.

**Reporting and analytics**

We provide access to both a replica of your production database as well as a pre-integrated SQL-based analytics tool. You can query all of the data and develop custom reporting as needed. Real-time access to your data is always available through our API.

**Borrower self-service**

Though not technically part of our repayment engine, our white-label, digital-native borrower portal helps maximize the impact of borrower self-service—and minimize the need for agent involvement. From any device, borrowers can easily check their balance, make payments, set up and customize autopay, modify their payment plan, access statements, update account information and more.

### 2. Automatically created collections cases

No matter how optimal your borrower self-service is, some accounts will go to collections. That’s where automatically created collections cases come in. With Peach, you can leverage your own operational insights to create sophisticated collections strategies that give you the best chance of collecting from each customer. Start by deciding when you want manual intervention to begin, which teams you want tasks assigned to, and how and when you want them alerted. Based on these rules, Peach will automatically create and distribute tasks among your available agents. Agents can then leverage the robust loan modification tools outlined above, and can set follow-ups such as scheduled outbound calls, manual email and SMS sends, and reminders to follow up.

Each of your teams can log in to Peach’s lending-specific CRM, where our system will match each team or agent to the unique actions they need to perform. For instance, your fraud team can be matched exclusively to dispute cases, while your legal team receives legal action cases. Meanwhile, the rest of your servicing team can continue performing their field work.

### 3. Automated collections campaigns

Recognizing that a mixture of contact methods is the most effective approach to collections, and that collections agents typically spend much of their time on repetitive tasks, we’re developing a new tool that will enable you to run automated and highly configurable collections campaigns. Available later this year, the tool will allow you to define which populations of borrowers you’d like to target, and then create rules as to when and how frequently you reach out—whether that’s through a phone autodialer or via email, text or direct mail—or a combination.

For outbound phone calling, Peach can help you match limited call center resources with positive answers to phone calls. After defining the borrowers you’d like to target—which you can update on an ongoing basis—Peach will export the requisite customer information to the dialer system of your choosing. As calls are made, the results will sync back into your existing collections cases in the Peach system, giving you a full picture of the attempts made on each borrower. You’ll get a full data analytics view, and results will also be visible within your agent tooling.

–

Our first-party collections tools are designed to help you approach the efficiency of a third-party collections agency while retaining 100% of what you collect. These collections tools are included standard as part of Peach’s servicing suite, alongside our [Adaptive Core™](https://www.peachfinance.com/platform/adaptive-core) and [Compliance Guard™](https://www.peachfinance.com/platform/compliance-guard).

To learn more about our first-party collections capabilities, [contact us](https://www.peachfinance.com/contact) or send us an email at info@peachfinance.com.


How Peach helps you master first-party collections

By now, most lenders with legacy servicing tech have come to the determination that it’s time to modernize. Some of them are driven by a desire to support new asset classes. Others want to drastically improve their customer experience, or consolidate functionality currently handled by disparate service providers.

Yet in spite of their conviction, a sizable percentage of these lenders have yet to move on from their legacy servicing platform. When it comes down to it, migrating their portfolio to a new system comes with risks and costs that can often be prohibitive. As a result, many lenders find themselves handcuffed to a legacy servicing platform they don’t want.

This quagmire is a result of servicers’ failure to modernize their portfolio conversion capabilities. Unlike servicing tech itself, which has undergone a renaissance in recent years, migrations remain one of lending’s most dreaded domains. On its face, this seems like a missed opportunity—wouldn’t servicers want to make it easy for new clients to migrate their portfolios? But the reality is that creating a low-risk and low-cost mechanism for migrations requires a degree of flexibility and automation that most servicing platforms fundamentally lack.

This is one of the reasons we pioneered the Adaptive Core™, a loan management system built for radical flexibility. This has given us a unique ability to rethink portfolio migrations—and to address the problems of risk, cost and timelines.

This fall, we’ll be releasing our free Self-Service Portfolio Migration™ tool—the first ever of its kind. For lenders stuck between the costs and benefits of migration, self-service migrations will be a game-changer. 

More on our solution in a moment—first, we’ll address the three main challenges with legacy lending portfolio migrations.

## Three challenges with legacy portfolio conversion methods

**Challenge 1: The risk**

Legacy portfolio migrations are typically conducted by a third party—either an outside vendor or your new servicing provider—working in collaboration with your internal team. The two teams migrate loans in batches, troubleshooting issues on a per-loan basis as they arise.

Because every system behaves differently in its terminology, interest accrual, rounding and status mapping, there’s a lot that can go wrong. And when migrations involve manual data entry—which they almost always do—errors are unavoidable at scale.

What’s more, migration processes are notoriously brittle, and unexpected discrepancies can arise in your data even after rigorous testing. Reconciliation down to the penny is painstaking work, and seemingly simple issues like rounding can cause your new and old systems to disagree. Minor inaccuracies can compound into unintended consequences for the borrower—for example, an inaccurate payment amount can result in an overdue status in your new system. These challenges can be compounded by migration methods that transfer only a snapshot of each loan, rather than the loan’s full history, making it much more difficult to rectify discrepancies as they arise.

A worst-case scenario is for your borrowers to log in and see missing or incorrect data in their account. This can jeopardize your customer relationships and expose you to compliance risk.

**Challenge 2: The timeline**

Because you’re dependent on your new servicer and potentially a third party to conduct your migration, you have limited control over your timeline. If your new servicing platform hasn’t invested in maximizing efficiency and preventing errors, the migration process can require a great deal of time and effort. It’s not uncommon for migrations to take 6-12 months or even longer.

When discrepancies do arise, it can be a challenge to gather the right people on both sides to troubleshoot and remediate the root cause. Many servicers have multi-quarter (or even multi-year) backlogs, which can leave you hanging when you most need help.

**Challenge 3: The cost**

Servicers often charge hundreds of thousands of dollars or more for portfolio migrations, depending on the size and nature of your portfolio. The first reason for the high cost is the manual nature of the typical migration process—and the fact that lending platforms are rarely designed to optimize migration efficiency. The second reason is that you’re paying for a third party to learn your current system—an investment that is not accretive to your business in the long run. 

By contrast, your own team is already familiar with your existing system, and they’re gearing up to learn your new one. So if they were empowered to conduct the migration themselves through a well-designed self-service tool, they’d need very little additional training. With automation to drastically reduce the total time spent, your team could achieve the same result in less time. The obstacle is that no lending platform has been designed for self-service until now.

## Peach’s Self-Service Portfolio Migration tool

Our Self-Service Portfolio Migration tool is a complete reimagining of portfolio migrations, giving lenders the ability to break free from their legacy tech stack without incurring unreasonable risks, costs and delays.

We’ve been planning self-service migrations for some time. They’re made possible by our Adaptive Core and by our Loan Replay™ technology, which makes it straightforward to insert events anywhere in the timeline, with recalculations happening automatically.

Self-Service Portfolio Migration empowers your own engineering team to conduct the migration to Peach. Using the same Peach APIs they’ll eventually use to interface with our system, they’ll call Peach’s typical endpoints. Once they verify that the migration is working for test users, your engineers can write simple scripts to automate the conversion process, eliminating the need for manual data entry. When the migration is complete, you’ll have access to all the benefits of the Peach platform, like our [Adaptive Core](https://www.peachfinance.com/platform/adaptive-core), [Loan Replay](https://www.peachfinance.com/platform/adaptive-core#loan-replay), [Compliance Guard™](https://www.peachfinance.com/platform/compliance-guard), [first-party collections capabilities](https://www.peachfinance.com/platform/servicing-suite) and more. The typical migration to Peach will take just 8-12 weeks.

The idea of our self-service migration isn’t to put more work on your team—it’s actually far less work than a traditional migration thanks to automation, efficiencies and error-preventing features of our self-service tool. And we’re here to provide migration assistance if you need us. Meanwhile, you get to remain in control of the migration timeline, and you’ll have close oversight of your data, reducing the likelihood of errors.

For those lenders whose capital markets providers require a backup servicer, Self-Service Portfolio Migration offers another important benefit. Typically, lenders will contract with a backup servicer that provides both software and agents. By decoupling the two and providing solely the software component, Peach can offer passive, real-time software backup at low cost, with no agent servicer needed except in a worst-case scenario. If you’re using Peach as your primary loan management system, this means you won’t need backup servicing software—just a backup agent servicer.

For lenders interested in the benefits of a modern, best-in-class lending platform, our Self-Service Portfolio Migration for the first time opens up the possibilities of modernization without the risks and drawbacks of legacy migration methods.

Self-Service Portfolio Migration will be available for **free**, starting in fall of 2022. To learn more, visit our [Self-Service Portfolio Migration page](https://www.peachfinance.com/migrate). You can also [contact us](https://www.peachfinance.com/contact) or send an email to <info@peachfinance.com>.


Peach to offer first-of-its-kind Self-Service Portfolio Migration™—at no cost

Fintechs, who have been this decade’s primary instigators of lending innovation, might seem poised to be the primary and perennial beneficiaries of continued technological progress. But things aren’t so straightforward. Many of today’s fintechs are falling into the same trap established lenders did long ago: They’re launching modern lending programs on rigid infrastructure designed for the present, not the future. We’ve seen the repercussions of this choice over the past decade, as established lenders hobbled by rigid infrastructure  ceded market share to fintechs, who have gobbled up  about half of all personal loan originations...

[READ THE FULL WHITEPAPER](https://www.peachfinance.com/documents/5-reasons-lenders-need-adaptive-infrastructure.pdf)


5 reasons lenders need adaptive infrastructure

Peach has been featured in Aite-Novarica Group’s Q2 2022 Retail Banking & Payments Fintech Spotlight. The report highlights nine vendors whose innovative offerings are putting pressure on legacy players.

The report underlines the ways Peach enables lenders to quickly launch highly configurable lending programs and to easily iterate on existing ones, even at scale. Three core differentiators are called out:

1.  Our Adaptive Core™, which gives lenders unprecedented flexibility in the configuration of lending programs and support for virtually any asset class.

2.  Our servicing solution, which is end to end and full integrated.

3.  Our compliance-first approach, with robust and innovative compliance technology in Compliance Guard™.

According to the report, Peach “...stands at the forefront of innovative solution providers capable of empowering financial services companies to adapt to the times.”

We’re proud to be featured in this quarter’s Fintech Spotlight. You can request a copy of the report from Aite-Novarica Group [here](https://aite-novarica.com/report/retail-banking-payments-fintech-spotlight-q2-2022).


Peach spotlighted in Aite-Novarica Group's Q2 report


Today, we’re announcing that we’ve renewed our certifications for SOC 2 Type 2 and PCI DSS Level 1, and that we’ve achieved certification for SOC 1 Type 1. These certifications position us to help a wide variety of lenders, including those at enterprise scale and with strict InfoSec requirements.

To achieve these certifications we worked with independent third-party auditors Laika and FoxPointe, who provided an important third-party validation of our internal and external processes and high level of operational excellence. The certifications complement our [Compliance Guard™](https://www.peachfinance.com/platform/compliance-guard) offering, which gives lenders an unprecedented advantage in staying compliant with lending regulations.

To learn more, read the [full press release](https://www.businesswire.com/news/home/20220606005550/en/Peach-Announces-SOC-2-Type-2-SOC-1-Type-1-and-PCI-DSS-Level-1-Certifications).


Peach announces InfoSec certifications


Today’s an exciting day at Peach—we’re launching our Adaptive Core™ offering, and we’ve also got a brand-new logo, visual identity and [website](/).

Our Adaptive Core is an entirely new paradigm in lending that will empower our clients to continually iterate on existing lending products, even at scale, and to launch innovative lending programs with speed and flexibility. Current Peach clients will automatically have access to the full breadth of functionality provided by Peach’s Adaptive Core.

Read more in our [press release](https://www.businesswire.com/news/home/20220523005291/en/Peach-Launches-Adaptive-Core%E2%84%A2-Announces-Rebrand).


Peach Launches Adaptive Core™, Announces Rebrand


Join us at LendIt Fintech USA next week, where Peach CEO Eddie Oistacher will be speaking about the keys to modern lending products. He’ll be joined by John Scrofano, a VP at Remitly in New Products, and moderator Hal Bienstock of Prosek Partners. The session will take place in Room 4 on Wednesday, May 25 at 5:05pm.

Peach will also be exhibiting at Booth 455.

#### About LendIt Fintech USA

LendIt Fintech USA is the leading event for innovation in financial services. Taking place on May 25-26 in the financial capital of the world, New York City, this event brings together the most innovative and disruptive financial services companies for 2 days of world-class content and face-to-face networking. Key topics include digital banking, web3, identity, consumer lending, embedded finance, financial health and much, much more. Save 15% on your ticket with code `SPONSOR15_PEACH`. For more information, visit [https://bit.ly/3utXHdY](https://bit.ly/3utXHdY).


Peach CEO Eddie Oistacher to speak at LendIt Fintech USA


We’re proud to officially announce our partnership with Mission Lane, helping power their Credit Builder Account—a new credit builder loan product aimed at setting consumers on the path to establishing strong credit.

Purpose-driven companies like Mission Lane that are pushing the boundaries of innovation in lending are helping create a better world for everyone. Learn more about the partnership in our [press release](https://www.businesswire.com/news/home/20220510006518/en).


Mission Lane Selects Peach to Power Inclusive Lending Products


We’re excited to announce that Peach has been selected as a launch partner for the Visa Ready for BNPL Program. This means that Peach will be readily available to any Visa clients looking to stand up BNPL capabilities.

Read the full [press release](https://www.businesswire.com/news/home/20220510005067/en/Peach-Selected-as-Visa-Ready-for-BNPL-Launch-Partner) for more information. Visa clients who would like to learn more about Peach can connect with us at info@peachfinance.com.


Peach selected as Visa Ready for BNPL launch partner


Today we’re spotlighting Russell Braden, our VP of Product. Russell is responsible for the suite of APIs that powers our modern loan servicing capabilities. That includes our expanding feature sets around payment processing, communications, agent tools, user portal and strategic partnerships. It also involves expanding our card program—partnering with leading card issuers to support a wide variety of physical and virtual card products for our clients.

Russell has previously held key roles at well-known companies like Grainger, Avant and Enova International. Most recently at Grainger, he oversaw Product Development for Customer Information, a cornerstone of Grainger’s broader digital transformation efforts. He helped scale insights and best practices from an internal startup across the entire company, replatforming their tech stack and reducing their dependence on legacy software.

Prior to Grainger, Russell was responsible for launching one of Avant’s installment lending programs—overseeing acquisition, underwriting, risk, servicing, collections and remarketing, as well as development of their servicing platform. And before Avant, Russell worked in Strategy & Operations at Enova International, learning the ins and outs of their online lending business through the lens of the call center.

“I’ve seen the severe customer pain caused by inaccurate and improper loan servicing,” Russell said. “And I’ve seen how resource-intensive corner cases can be. Manual operations has always been a fact of life for lenders—but Peach has managed to turn this on its head. Peach’s modern servicing platform helps eliminate or significantly reduce the manual processes needed to run a successful lending business, helping lenders increase both profits and customer satisfaction.”

Peach’s ability to leverage technology to solve common pain points is in part due to its position at the crucial intersection of borrowers, operations and servicing technology. It’s also due to a very intentional focus on solutions that are scalable to many asset classes and types of lenders, and are configurable enough to feel custom to both agents and borrowers.

“We’re leveraging technology to solve pain points many lenders have dealt with for decades,” Russell said. “But it doesn’t stop there. Our technology platform also unlocks lenders’ ability to innovate. Whether it’s speed, flexibility or robust functionality, we’re continually focused on delivering a product suite that is technologically differentiated.”

Eddie Oistacher, CEO of Peach, added: “The pace of change in lending is accelerating, and it’s our job to empower lenders to innovate ahead of the curve—today and into the future. So we have to be two steps ahead, building the infrastructure for continued innovation.”

“That’s the real importance of Russell’s work,” he went on. “Russell is ensuring that we can support clients as they push the envelope, expanding our features and functionality as well as our support for asset classes and client types. Russell has seen what success and failure look like across origination, servicing and collections, and he has the vision to help us point lenders of all kinds in the direction of success.”

Outside of work, Russell is an avid athlete—most recently channeling his passion for sports into platform tennis. Russell lives in Chicagoland with his wife and three kids.

**Curious about Peach? We’d love to talk—we’re at [info@peachfinance.com](mailto:info@peachfinance.com).**


Leadership Spotlight: Russell Braden, VP of Product


Whether you’re buying or building the customer relationship management (CRM) technology for your lending program, there are some important ways in which it should differ from a general-purpose CRM. Here are 9 key features to look for that will help you lower your servicing costs and increase agent and borrower satisfaction.

#### 1\. Omnichannel communications

A modern approach to servicing means having a CRM that supports a wide variety of communications channels, including email, SMS (including two-way texting), chat and direct mail. You’ll want asset class-specific default cases, workflows and templates that are vetted by industry and compliance experts. For instance, if a customer reaches out via email to say that they’ve declared bankruptcy, agents should receive predefined workflow steps and communications templates out of the box—ensuring consistent application of your policies and compliance with applicable bankruptcy laws. You’ll also want the flexibility to configure your own cases, workflows and templates as your lending program scales.

#### 2\. Compliance built in

Lenders know that complying with federal, state and local regulations—including the recently implemented [Reg. F](https://blog.peachfinance.com/posts/how-peach-helps-lenders-comply-with-regulation-f/)—is as important as it is challenging. That’s why you’ll benefit from a CRM that automates much of the complexity in meeting your servicing and collections compliance requirements.

Your CRM can help you take proactive steps to support borrowers during significant life events by monitoring borrower accounts for bankruptcy, death, active military duty, and federally declared disasters. The CRM can automatically provide legally required protections, proactively offer hardship solutions and receive automatically generated cases for review.

Your CRM should also check outbound communications for compliance with servicing regulations and borrower preferences, providing you with default rules that you can further configure. It should automatically block communication attempts that are in violation—for instance, a collections call during a time when a borrower has expressly asked not to be contacted.

#### 3\. Support supercases

The future occurrence of natural disasters, pandemics and the like is an unfortunate but inevitable reality. That’s why your CRM should support automatic monitoring of FEMA disasters, and enable you to cluster impacted customers and generate corresponding cases and notes. Likewise, you’ll want to be able to cluster do-not-interact rules to avoid inappropriate servicing and collections communications during disasters. The alternative, which is still a reality for many lenders today, is to rely on spreadsheets and manual processes—a resource-intensive approach that’s prone to human error.

#### 4\. Enable remote servicing

Though the need to support remote work arose seemingly overnight, it’s now mandatory for many employers—not to mention cost-effective. Whether or not your agents are currently working from home, a CRM that supports remote servicing is at minimum an important hedge against future remote-work needs. Look for a CRM that’s cloud-hosted and browser-based, where agents need only a computer and an internet connection. From an information security perspective, your CRM should support multi-factor authentication, data encryption, role-based access, real-time security monitoring and a strong password policy.

#### 5\. See what the borrower sees

Many servicing platforms give agents an entirely different interface than what borrowers see. In reality, though, there isn’t any reason the agent and borrower interfaces need to be fundamentally different. A better approach is to give agents the same view as borrowers—just with augmented capabilities—so that agents intuitively understand the borrower experience and can more easily guide borrowers toward self-service actions.

#### 6\. Robust and modern borrower self-service

Though not a CRM feature per se, robust and intuitive borrower self-service features—enabling borrowers to easily make and schedule payments, update account information, customize their payment plan and more—have a direct impact on servicing costs by reducing customer contacts and simplifying resolution. A thoughtfully designed borrower portal can increase repayment rates, improve the customer experience, and make borrower actions quicker and easier—benefits that accrete both to your brand and to your bottom line.

#### 7\. Superior agent experience

It sounds obvious, but it’s not a given in most lending CRMs—the experience of your agents deserves as much attention as the experience of your borrowers. When your CRM accords with the same user experience principles as your borrower portal, training can happen more quickly, agent efficiency and satisfaction rise, and resolution times are reduced. Not to mention that the positive experience of your agents will inevitably translate to a better experience for your end customers.

#### 8\. Fully integrated tools

Most lenders have separate servicing, CRM and ticketing systems—requiring agents to toggle between multiple windows to execute even basic tasks. This approach should be avoided because of negative impacts to data consistency, resolution time, agent satisfaction and vendor costs. Instead, look for an integrated, all-in-one solution where your CRM and servicing systems stay in sync by default. Your CRM should know of open cases, update information seamlessly between systems and automatically check actions for compliance.

#### 9\. Smart case matching

When your servicing system and CRM talk to each other, you can distribute work in efficient and powerful ways. This unlocks team ownership of tasks and cases, eliminating dependency on a single agent. Your task system can automatically distribute work by matching it to appropriately skilled agents, and the first available agent can then take the work and triage from a shared task queue.

**Lenders can get by without some of these features, but it will likely come at the expense of efficiency, resolution times, and agent and customer satisfaction. In today’s advanced lending technology ecosystem, there’s no reason your CRM can’t deliver on all these key features, enabling you to maximize efficiency and keep servicing costs down.**

**If you’d like to learn more about Peach’s CRM, send us a note at [info@peachfinance.com](mailto:info@peachfinance.com).**


Your lending CRM should have these 9 features


Here at Peach, we’re proud to have added two key members to our leadership team: Russell Braden joins as VP of Product, and Dr. Anurag Ojha joins as Chief Information Security Officer.

In his Product role, Braden will focus on financial products—continuing to build out Peach’s robust feature set around payments, communications, agent tools, user portal, strategic partnerships and more.

Braden joins from Grainger, where he oversaw Product Development for Customer Information, a cornerstone of Grainger’s broader digital transformation efforts. Prior to Grainger, Braden held key roles in Product and Strategy & Operations at fintech lenders Avant and Enova International.

“Investment in Product is and always has been central to our mission,” said Eddie Oistacher, CEO of Peach. “A loan management and servicing platform that’s as modern and configurable as ours requires technical expertise, thoughtful design and continuing investments in feature development to deliver a product fit for enterprise clients. Russell Braden brings expertise in all these areas, plus practical experience building lending programs at some of today’s best-known fintechs.”

On the InfoSec side, Dr. Anurag Ojha brings over 20 years of experience building and scaling information security programs for leading banks and fintechs. Ojha will lead the design and strategy of Peach’s information security program, with a focus on best practices in security governance and compliance.

Ojha most recently led the global security program at CentralSquare Technologies. Prior to CentralSquare, Ojha established and managed security programs at other technology companies and fintechs, including NetApp ONTAP and Wipro.

"Our role as a critical technology solution for the financial services industry is not something we take lightly,” said Shara Chang, Peach’s General Counsel and Chief Compliance Officer. “As remote work becomes the new normal and data security takes center stage among financial regulators' supervisory priorities, Dr. Anurag Ojha's visionary leadership and hands-on experience managing regulatory audits will significantly advance Peach's vision of being a trusted compliance partner to our clients.”

Braden and Ojha join Peach’s existing leadership team, which includes CEO Eddie Oistacher, CTO Eran Sandler and COO Gur Brosh. Other members of the leadership team include Shara Chang, General Counsel and Chief Compliance Officer; Noah Trugman, VP of Sales and Partnerships; and Dave Waller, VP of Enterprise Sales.

**If you’d like to learn more about how Peach can help you launch new lending programs and automate compliance monitoring, email us at [info@peachfinance.com](mailto:info@peachfinance.com).**


Peach Adds Senior Leaders to Bolster Product, InfoSec Capabilities


The CFPB’s new debt collection rule, [Regulation F](https://www.consumerfinance.gov/rules-policy/regulations/1006/) (Reg. F), lays out important requirements for lenders, servicers and debt collectors. Because Reg. F just recently took effect, we wanted to expand on our [previous Reg. F blog post](https://blog.peachfinance.com/posts/what-the-cfpb's-new-debt-collection-rules-mean-for-creditors-and-first-party-servicers/)—and to outline some of the ways we’re helping alleviate the Reg. F compliance burden for our customers through smart automation and forward-looking product development.

## Who Needs to Comply with Reg. F?

Reg. F is the implementing regulation of the Fair Debt Collection Practices Act (FDCPA), which is written to apply to “debt collectors.” While this seems to exclude creditors and first-party servicers, these entities can in fact be in violation of certain FDCPA requirements according to longstanding [CFPB guidance](https://files.consumerfinance.gov/f/201307_cfpb_bulletin_unfair-deceptive-abusive-practices.pdf).

As a result, many banks, credit unions, and fintech lenders and servicers have decided it’s important to comply with at least some of Reg. F’s new requirements. For your organization, the decision ultimately comes down to risk tolerance.

## What Parts of Reg. F Pose the Greatest Implementation Challenges? 

Reg. F introduces several new requirements, including call frequency limits, text and email rules, model validation notices, and additional disclosures. In our prior blog post, we talked about how [Peach](http://www.peachfinance.com/) helps lenders and servicers comply with call frequency limits. Now we’ll cover our approach to two additional provisions that present major implementation hurdles: (1) compliance with “inconvenient time and place” requirements, and (2) safe harbor procedures for text messages and emails.

### Challenge 1: Inconvenient Time and Place Requirements 

It’s well known in the industry that the FDCPA prohibits debt collectors from contacting consumers for debt collection purposes between 9 p.m. and 8 a.m. But Reg. F clarifies that the FDCPA’s statutory language is actually significantly more restrictive.

- **Consumer-Designated Preferences.** Reg. F states that a debt collector cannot contact a consumer for debt collection purposes at any time or place “known or which should be known to be inconvenient to the consumer.” This puts the onus on the debt collector to honor consumer requests regarding when and where they want to be contacted. For example, a consumer might ask not to be contacted between 3–5 p.m. on Tuesdays.
- **Conflicting Information on the Consumer’s Location.** Reg. F adds that if a debt collector has conflicting information about a consumer’s local time zone, it can’t attempt to communicate at a time that would be inconvenient in any of the consumer’s possible locations.

### Challenge 2: Safe Harbor Procedures for Text Messages and Emails

Reg. F confirms that text messages and emails can be used for debt collection purposes. At the same time, debt collectors have a responsibility to prevent unintentional third-party disclosures of debt. While debt collectors are free to implement their own procedures, Reg. F outlines specific ones that provide safe harbor protection against unintentional third-party disclosure claims brought under the FDCPA.

## How Peach Helps Creditors and Servicers Comply with Reg. F 

One of the challenges with legacy solutions is that most lack a thoughtful and ongoing commitment to compliance. As regulations evolve, these legacy solutions typically require significant resource investments to power manual processes and ad-hoc solutions.

By contrast, Peach allows creditors and servicers to swiftly implement an automated plan to comply with new federal and state requirements. You can instantly turn on any of our new Reg. F capabilities.

### Solution 1: Inconvenient Time and Place Requirements 

Peach’s proprietary Compliance Guard™ solution automates compliance for inconvenient time and place requirements. We capture consumer-designated preferences on inconvenient times and places and issue an alert to block any communication attempts that would be in violation. Compliance Guard also scans multiple borrower data points to ensure that outbound communications are made during compliant periods if there’s ambiguity about where the borrower resides. Compliance Guard applies to debt collection calls, texts and emails.

### Solution 2: Safe Harbor Procedures for Text Messages and Emails

Peach makes it easy for organizations to take advantage of Reg. F’s new safe harbor protections for text messages and emails if they choose.

- For **text messages**, Peach’s Compliance Guard modules have been updated to obtain re-consent from consumers and to provide scanning of the Federal Communications Commission’s Reassigned Numbers Database to confirm that phone numbers have not been reassigned. As with other automated rules, Compliance Guard would recommend blocking any non-compliant text messages.
- For **emails**, Peach’s platform already tracks consents and opt-outs, ensuring that consumer requests are promptly stored and honored.

\* \* \*

While Reg. F introduces additional regulatory complexity for lenders and servicers alike, and raises the stakes for staying compliant, Peach’s compliance-by-design approach makes it easy for our customers to stay ahead of ever-evolving regulations like Reg. F.

**If you’d like to learn more about how Peach can help your organization automate compliance while providing a best-in-class servicing experience, email us at [info@peachfinance.com](mailto:info@peachfinance.com).**


How Peach Helps Lenders Comply with Regulation F


At [Peach](http://www.peachfinance.com), we work with many early-stage fintechs looking to launch new lending products. A common question they face is whether to buy a piece of the lending technology stack or build it in-house.

These fintechs are technology companies themselves, with strong in-house product and engineering teams. So it’s no surprise that they’re often strongly inclined to build. Here’s how we help our customers think about this decision with regard to servicing tech specifically.

The first question is: What functions are core and differentiated to your business? Our view is that in lending there are two core differentiators: 1) marketing and customer acquisition, and 2) underwriting and risk management. Though loan servicing is an important part of the lending business, it isn’t core or differentiated.

From an investment standpoint, our customers typically find that it isn’t a good use of engineering resources to build and maintain a proprietary servicing platform. At least not if there’s a flexible, modern servicing technology partner that can support the needs of your current and future lending products without months of customization effort.

Fintechs who come to this view naturally gravitate toward a partner like Peach that specializes in modern servicing technology and gives lenders a choice between a true all-in-one solution (including system of record, payment processing, white-label borrower portal, CRM and compliance) and modules with open APIs they can build on top of.

Other fintechs go through the exercise of measuring and comparing the costs of buying versus building. However, the cost to build servicing technology is surprisingly difficult to forecast, for a few reasons.

First, lending products often start off simple—no interest accruals or fees, simple terms, single repayment method, etc. The requirements (and costs) for your servicing tech will grow as your product requirements change. Second, servicing tech has many constituents, including finance and accounting, credit risk, operations and collections, legal and compliance, and capital markets. And don’t forget about your end users! Building technology that truly works for all these stakeholders is not easy or cheap.

And third, approximately 90% of your servicing costs will come from 10% of your customers. Within that 10% group are many different cases you’ll have to deal with—payment failures, product returns, bankruptcies, identity theft, active military cases, FEMA federal disasters and identity theft, not to mention hardship and loan modifications (which can be forward-looking or retroactive). To forecast accurately you have to plan for every corner case and build these into your cost model in advance. It’s difficult to do this if you haven’t built a servicing system before.

That’s why we built Peach. Peach is the third generation of the modern servicing platform our team has worked on at companies like Affirm, Enova International, and Prosper. We support a wide variety of asset classes, including credit cards, charge cards, cash advances, BNPL/POS, RISAs, personal loans (installments and lines of credit), home improvement loans, private student loans, business loans, MCAs, and auto loans and leases.

Our loan management system has 150+ configuration variables that define loan product behavior. We can configure new loan types in a day and launch new lending programs in weeks. And if your requirements change or you want to launch a new product, we’re well-positioned to support your growth.

We love consulting with early-stage fintechs! If you’re planning to launch a lending product, please connect with us at [info@peachfinance.com](mailto:info@peachfinance.com). We’d love to hear from you.


Fintechs - Buy or Build?


The CFPB’s final rules on debt collection issued in October and December 2020 have left creditors and servicers wondering what to do with them. These rules were the result of a 7-year long process and represent the first major rulemaking under the Fair Debt Collection Practices Act (FDCPA) since the law’s inception over 40 years ago. Even with the rules finalized, as described in greater detail below, incoming CFPB leadership has questioned whether the final rules need to be further refined.

By definition, creditors and first-party servicers are excluded from coverage because they are not “debt collectors” under the FDCPA. But even then, creditors and servicers comply with many FDCPA requirements in large part due to longstanding [CFPB guidance](https://files.consumerfinance.gov/f/201307_cfpb_bulletin_unfair-deceptive-abusive-practices.pdf) stating that entities that are not debt collectors could still violate consumer protection laws by engaging in conduct prohibited by the FDCPA. The CFPB’s powers to enforce such violations would not come through the FDCPA itself, but through the CFPB’s broad powers to prohibit unfair, deceptive, or abusive acts or practices (UDAAPs).

One of the notable requirements under the final rules effectively proposes 2 distinct limits on how often debt collectors can call consumers. Subject to limited exceptions, the final rules create a presumption that a debt collector violates the FDCPA if it (a) calls a person more than 7 times within 7 consecutive days; or (b) calls a person within 7 days of having a phone conversation with that person. These limits apply at the per-debt level, with the exception of student loans which may be aggregated by account number.

In the 1000+ pages of the rules’ text, the CFPB expressly refused to apply the new rules to creditors and first-party servicers or take a position on whether any conduct under the rules could give rise to a UDAAP. However, much could change between now and the rules’ effective date of November 30, 2021. The CFPB Director who issued the final rules, Kathy Kraninger, stepped down from her post at the request of the Biden administration in January and is expected to be succeeded by FTC Commissioner Rohit Chopra. On several occasions, FTC Commissioner Chopra has publicly expressed his views that the final rules don’t do enough to protect consumers from abusive debt collection practices. In particular, he has [opined](https://www.ftc.gov/system/files/documents/public_statements/1544795/chopra_-_comment_submission_on_cfpb_proposed_debt_collection_rule_9-18-19.pdf) that the new phone call frequency limits “seem excessive” and has [admonished](https://www.ftc.gov/system/files/documents/public_statements/1583802/chopra_statement_for_midwest_recovery_systems.pdf) the CFPB for failing to follow through with its plans to regulate first-party debt collection practices. Earlier this month, Acting CFPB Director Dave Uejio directed CFPB staff to explore options for preserving the status quo with respect to the debt collection rules, sending a strong signal that the final rules could be delayed until the CFPB implements more consumer-friendly requirements with FTC Commissioner Chopra at the helm.

With these developments, the risk is apparent that the CFPB under a new presidential administration will eventually apply at least some aspects of the final rules to creditors and first-party servicers. Prudent creditors and first-party servicers will need to assess the potential impact the final rules could have on their operations and whether, and the extent to which, they might proactively comply with some of the new requirements, at least as we understand them today.

At a time when applicable regulatory requirements appear uncertain and subject to swift amendment, more creditors and servicers are turning to [Peach](http://www.peachfinance.com). Peach has developed a [suite of services](https://www.peachfinance.com/platform/compliance-guard) to help creditors and servicers achieve compliance with the complex web of requirements that apply to the servicing and collection of consumer purpose credit. For instance, Peach’s Compliance Guard - Rules module checks outbound servicing and collections-related communications against federal, state, and local laws that apply to creditors and servicers. The Compliance Guard - Rules module automates compliance for requirements under the FDCPA (including unusual time and place restrictions and limitations on third-party contacts) and already incorporates existing call frequency limits in jurisdictions that require them, such as Massachusetts and New York City. As part of the onboarding process, Peach presents creditors and servicers with its catalogue of pre-programmed business and legal rules, which in coordination with Peach, can be tailored to meet a company’s operational needs and risk tolerance. Once in action, Compliance Guard - Rules smartly selects applicable rules by loan type, licensure, servicer or creditor’s charter, and borrower’s state of residency. If the Compliance Guard - Rules module determines that a proposed communication would violate a legal or business requirement, it will recommend blocking the communication attempt.

If you’d like to learn more about how Peach can help creditors and servicers automate compliance, while providing a best-in-class servicing experience, email us at [info@peachfinance.com](mailto:info@peachfinance.com).


What the CFPB's new debt collection rules mean for creditors and first-party servicers

We’re excited to announce that [Shara Chang](https://www.linkedin.com/in/shara-chang-20b27b16/) has joined [Peach](/) as our General Counsel & Chief Compliance Officer.

Shara’s addition will enable us to build and scale our lending and servicing systems with compliance considerations at the forefront. Because one of our main value-adds for lenders is mitigating compliance risk, our own investment in legal and compliance personnel is critically important. Our solutions incorporate federal and state laws in a way that keeps lenders compliant on all fronts while at the same time helping borrowers maintain or improve their financial health.

Shara brings keen insight into lending regulation, technology, payments and privacy. She previously helped Affirm, Inc. scale its lending products to millions of borrowers while successfully navigating a shifting regulatory landscape. Her exceptional knowledge of lending product functionality will help us build and deliver state-of-the-art solutions that are true innovations never seen before in market.

“Loan servicing has been a priority for federal and state regulators and we should expect an intensified focus in this space, particularly in today’s economic climate where borrowers with financial hardships need flexible repayment options to get by,” Shara said. “Peach’s suite of services features a sleek servicing platform that unlocks these options for borrowers and automated tools that help lenders navigate the patchwork of federal and state laws impacting their servicing operations. I look forward to leveraging my experience with disruptive tech companies and leading financial institutions to help Peach deliver on its strategic initiatives and modernize the loan servicing industry.”

We couldn’t be more excited to welcome Shara to the Peach team!

About [Shara Chang](https://www.linkedin.com/in/shara-chang-20b27b16/):

Shara brings 10+ years of experience in financial services and consumer protection law, having advised leading tech companies, fintechs and banks on product development, risk management, regulatory compliance and enforcement. Before joining Peach, Shara led a team of privacy lawyers at Facebook that advised on global payments, research and integrity initiatives. Shara was the first and lead Product Counsel at San Francisco-based fintech Affirm, and worked in private practice at Buckley LLP and at Cleary Gottlieb. She has also held leadership roles in the American Bar Association’s Banking Law and Consumer Financial Services Committees.

About [Peach](/):

Peach is an Oakland-based startup providing modern loan management and servicing software for lenders and servicers. Our system is entirely post-origination and manages the loan until pay off or write off. We provide the financial ledger (system of record), payment processing, borrower portal, communications, CRM for collections, and compliance.

#### Key benefits:

*   **A+ Borrower Experience**: Peach provides a simple and intuitive white-label portal where borrowers can access and modify their loans from any device.

*   **Lower OpEx**: Peach’s comprehensive, easy-to-use suite of agent tools allow for fast agent training, expedited customer issue resolution, and lower agent turnover. Peach’s machine learning models also optimize collections strategies.

*   **Eliminate Compliance Risk**: Our proprietary Compliance Guard software conducts monitoring and real-time checks on federal and state regulations to ensure you stay compliant.

*   **Faster Go-To-Market**: Peach consolidates 5 systems in a single, integrated platform. Lenders can configure 80+ variables and launch new loan products in under one hour. Modern APIs allow quick integration with the lender's origination system.



Announcing Peach's New General Counsel

### How to Prepare Your Servicing Operation for a Post-Pandemic World

The dual public health and financial crises set off by COVID-19 has created unforeseen challenges for both borrowers and lenders. In a [previous post](/blog/covid-19-part-1-helping-borrowers-through-hard-times/), we highlighted how Peach’s modern loan servicing platform can provide flexible payment plans and loan modification options to borrowers in times of emergency. In this post, we’ll address the challenges lenders face in converting servicing call centers to remote-work operations—and how Peach’s software solutions can make this transition easy.

#### The Challenges of Remote Work

The recent COVID-19 outbreak has transformed call centers into potential transmission zones, creating health risks for workers. Regardless of whether states [allow call centers to remain open](https://www.insidearm.com/news/00046043-new-state-shelter-place-orders-shut-down-/), we believe all lenders need to be able to quickly shift servicing operations to remote work where legally possible to protect the health and safety of their employees—and to ensure business continuity.

However, this shift to remote work creates challenges that span across operations, technology, privacy, data security and compliance. Agents need remote access to servicing systems and tools to interact with borrowers while still protecting borrowers’ data in a home environment. Supervisors need to maintain the ability to audit and monitor agent performance for quality. Back office personnel need escalation tools, audit trails, and controls to ensure compliance.

[Peach’s](http://www.peachfinance.com) modern loan management and servicing platform addresses these challenges and gives lenders a push-button option to enable call center agents to work from home.

#### How Peach Enables Remote Work

Peach’s servicing platform is a scalable cloud-hosted solution (built on Google Cloud). That means anyone with internet access can be granted access to the system, including those with VoIP connections (without the need for VPN interference). Call center agents working remotely just need to connect an employer-provided computer to the internet and log in to Peach. The Peach application runs in the browser, so even a basic laptop is sufficient.

For each job function, Peach provides the tools and data employees need to do their job.

For agents, Peach provides an integrated suite of servicing and collections tools including a loan management system, a customer relationship management (CRM) system, cases and workflows and communication tools.

For supervisors, Peach provides real-time performance and SLA reports, call analytics, and recordings so supervisors can coach agents, monitor trends, and ensure quality.

For back office and compliance personnel, Peach provides access to real-time data and audit trails.

Peach provides a full set of controls and permissions to restrict agent access to shift hours. We also run velocity checks to prevent data abuse, prevent data from being inappropriately copied or downloaded, and ensure agents are working from an approved remote location.

#### Scaling and Training for Increased Demand

Current and future public health crises may stretch the limits of existing call-center capacity and create the need to onboard temporary workers. Legacy servicing systems are difficult to learn and take weeks of in-person training to use properly. Peach provides servicing tools that are intuitive and easy for agents to use. New agents can be trained on the Peach platform in days, not weeks, to allow lenders to quickly scale up to meet increasing demand.

If you’d like to learn more about how Peach helps lenders modernize their servicing operation, please email us at <info@peachfinance.com>.

### ****

**About Peach**

Peach is a cloud-native lending technology platform that helps fintechs and traditional financial institutions quickly launch new lending programs. Peach is the only lending platform built on an Adaptive Core™. The company’s fully integrated suite of API-based products includes a loan management system that supports virtually any non-mortgage asset class and features 200+ configuration variables; a suite of proprietary servicing tools, including a lending-specific CRM, borrower portal, agent portal, payment processing, communications, reporting and first-party collections tools; and Compliance Guard™, a proprietary compliance monitoring system. Peach can also accrue interest and generate repayment schedules during loan origination. Peach was built by leaders from top fintechs like Affirm, Avant and Prosper, who set out to create the most configurable, robust, compliance-forward and future-proof lending platform in the market. Learn more at [peachfinance.com](https://cts.businesswire.com/ct/CT?id=smartlink\&url=https%3A%2F%2Fwww.peachfinance.com%2F\&esheet=52740188\&newsitemid=20220606005550\&lan=en-US\&anchor=peachfinance.com\&index=1\&md5=31f321d027ee89a322323dcfb6c40aa8).


COVID-19 Part 2 - How to Prepare Your Servicing Operation for a Post-Pandemic World


### Helping Borrowers Through Hard Times

The COVID-19 public health crisis has created unprecedented challenges for borrowers, lenders and servicers. This post focuses on how lenders and servicers can leverage Peach’s solutions to help borrowers in times of emergency and financial hardship.

### What Borrowers Need

The full impact of COVID-19 on the economy is uncertain. But in the past few weeks, millions of workers have lost their jobs and small businesses are running out of capital. The federal government is racing to send checks to households, extend [loans to small businesses](https://www.inc.com/brit-morse/sba-loans-coronavirus-stimulus-package-cares-act.html), and encourage banks to start offering [responsible small dollar loans](https://news.bloomberglaw.com/banking-law/bank-regulators-urge-small-dollar-lending-in-covid-19-crisis) to consumers. Federal and state governments are encouraging lenders to offer flexible accommodations to borrowers impacted by COVID-19.

As economic conditions deteriorate and borrower delinquencies increase, lenders need powerful tools to provide borrowers with flexible payment plans and loan modification options.

Most legacy servicing systems are too rigid to accommodate custom hardship programs, or they require significant manual work by back office personnel. This is costly and does not scale. We built Peach to provide greater flexibility. With Peach, you can deploy a wide range of tools to respond to borrower hardship, benefiting both borrowers and lenders.

### What Peach Enables

Peach’s solution gives lenders and servicers various ways to handle hardships and loan modifications, including the ability to:

1.  Defer due dates to a future date, either within an existing loan term or with an extended term.
2.  Lower interest rates and suspend late fees.
3.  Pause collection efforts, including calls and/or overdue notifications.
4.  Lower recurring payment amounts by changing due date frequency.
5.  Lower recurring payment amounts by extending loan duration.
6.  Allow borrowers to prepay future recurring payments.
7.  Offer settlement plans to prevent charge-offs.
8.  Automatically execute a natural disaster relief plan according to lender specifications.
9.  Report loans as current to credit bureaus if the consumer fulfills the terms of the accommodation.

Peach automatically recalculates and/or re-amortizes in real time, allowing customer care agents to go over revised numbers and find the best solution for the borrower. There’s no custom code required.

### Automation and Self-Service

Many of these features can be enabled in Peach’s white-label borrower portal as self-service actions for borrowers. Giving borrowers the ability to modify loans on their own gives them control and eases their burden in difficult times. This can significantly lower the load on customer care and collections teams, allowing them to focus on the most difficult cases.

In our [next post](/blog/covid-19-part-2-how-to-prepare-your-servicing-operation-for-a-post-pandemic-world/), we address the challenge of keeping call centers operational during a crisis and how lenders can shift quickly to remote-work operations for loan servicing.

If you want more flexible ways to accommodate borrowers’ financial hardship, please email us at [info@peachfinance.com](mailto:info@peachfinance.com)


5 reasons lenders need adaptive infrastructure

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