Indirect Looks to Lead Again in Lending Dance
The momentum should have led to programs that helped aid bottom lines across the country. Instead, that rapid growth caused some credit unions’ indirect loans to destruct, brought on by a high concentration, massive defaults, shady incentive programs and poor dealer relationships. The latter likely was the worst culprit, some have argued.
“One thing that all the credit unions that got in trouble have to remember is that it they had no one to blame but themselves,” said Eddie Nevarez, vice president of business development for the National Auto Loan Network, in Newport Beach, Calif., which counts more than a dozen credit unions among its clients.
“It is no secret that auto loans and memberships are the bread and butter for all credit unions, but back then, many were risking their members on plain bad lending practices to satisfy their indirect lending partners,” Nevarez said.
Nearly all–Nevarez estimated 99.99%–of credit unions involved in indirect lending got caught up in the idea that auto loans were the end all and be all of success. As a result, they let the dealers dictate to them their business.
“It is not so shocking to hear what they have to say regarding a few credit unions in Southern California, most of which stopped their indirect programs and recently started back up or are looking to get back in to indirect lending,” Nevarez said. “The one thing that these individuals all say is that there were credit unions that would buy anything and if you could not get approved anywhere else we knew that these credit unions would approve or buy it.”
From firsthand experience with one of these California credit unions, Nevarez said that most of the due diligence needs to be done internally. That can mean ensuring that a credit union is staffed properly to handle an indirect program and keeping the underwriting guidelines consistent with the credit union’s direct program, he advised. Internal controls are a must including audit and compliance procedures, Nevarez noted.
On the other end, providing the indirect partner with clear expectations can prevent surprises. Underwriting guidelines, funding and service levels and turnaround times need to be spelled out.
“Set the criteria of the program and only sign with partners that agree with your terms,” Nevarez said. “Always remember that the members come first.”
After heavy losses, the $582 million Seattle Metropolitan Credit Union shut down its indirect lending program in 2009, said Caleb Cook, vice president of lending.
“The spreads are very thin for all loans in the current environment, and margins must be managed closely. Indirect loans should be looked at as an investment as many of the new members you sign up will be single service,” Cook said. He added that credit unions may want to shoot for a 1% margin considering they can get a 1% return on a risk-free investment.
Indirect lending comes in all shapes and sizes, from small to large programs to in-house operations or through partnerships with a CUSO or for-profit organizations. Because a program can include autos, boats, recreational vehicles or even merchant lending, Cook said a sturdy foundation should be the common goal.
“The level of due diligence required before implementing an indirect lending program depends on the shape and scope of the operation,” Cook said. “Implement prudent risk and portfolio limits and closely monitor performance as your program matures, which generally takes two or more years. Document all of your due diligence as the examiners will ask to review during their next visit.”
Critical strategies to ensure credit union long-term success in indirect lending should begin with having the goal of starting slow and growing steady, said Michael Cochrum, product director of analytic products for CU Direct Corp., a lending service provider in Ontario, Calif., with 1,050 credit union clients.
“When new loan originations are down, it’s tempting to hook up the lending hose to the nearest origination hydrant and turn it on full blast,” Cochrum said. “But the key to long-term success in indirect lending is to set reasonable goals for growth and not be tempted to take on more than your credit union can handle.”
Fast growth can hide performance issues early on, so it’s important to be able to segment risk categories by origination period in order to isolate emerging negative indicators, he pointed out.
Another area where credit unions may get into trouble is weighing relationships over rates, Cochrum said. Because they are not positioned as top-tier lenders at the dealership, the temptation is to compete for business by offering the lowest rate, he noted.
“This can obviously cause profitability issues down the road. Relationship trumps rate in the dealer [finance and insurance] office, especially in the low-rate environment we are in today. An F&I director can sell a 50 basis points difference in rate,” Cochrum said. “It’s what they do. More important than rate is consistent underwriting, timely funding and the ability to share in the profits of closing the loan.”
If credit unions maintain a consistent underwriting standard, eliminate needless delays in funding and provide the opportunity for the dealer to profit from the arrangement, they can sustain long- term relationships with dealers, Cochrum said.
“Remember, the dealer has no reason to protect the lender if they are only doing 1% to 2% of their loans with your credit union,” Cochrum warned.
Meanwhile, as the concentration of financial penetration builds, another lure might be trying to do business with every dealer in town. Cochrum said most credit unions can get the volume required for a solid performing portfolio from 10 to 15 dealer relationships. However, it’s better to get five to 10 loans from 10 to 15 dealers than one loan from 100 dealers, he offered.
“When a credit union has gained penetration in a dealership, they are vested in the relationship and the credit union becomes integral to their success. A dealer is much more reluctant to fracture a relationship in this case,” Cochrum explained. “If your credit union is only doing one or two loans a month with a dealer, then that only represents incremental business. If the relationship is fractured, it is easily replaced by another financial institution.”
Above all else, credit unions have to stay on top of consistently monitoring risk factors. The set it and forget it approach can lead to problems down the road, Cochrum said. For instance, sharp increases in volume can indicate a soft spot in a credit union’s underwriting that may be exploited, he suggested.
Monitoring the mix of paper a credit union is getting and how long members in each credit tier are sticking with can help indicate areas where long-term profitability may also be challenged, Cochrum advised. While there is encouragement to monitor dealer losses and delinquencies, it might be even more telling to monitor a finance director’s performance as they move from dealer to dealer, he noted.
“Credit unions must monitor volume fluctuations, credit quality distribution, lifecycle yields, early payoffs, first payment defaults, finance director portfolio performance, and underwriter and dealer loan pools,” Cochrum said. “These are the areas that can indicate trouble.”
NCUA examiners are reviewing call reports for increasing amounts of repossessed autos or increasing indirect lending delinquency and loan losses, the agency has reminded in several letters to credit unions including an August 2010 on due diligence.
In addition to those danger signs, examiners are also looking for other red flags that may require a credit union to slow down indirect lending. Among them is a high concentration of indirect loans to total loans or net worth without adequate controls in place and incentive programs tying loan officer bonuses to indirect loan volume.
The NCUA said other areas of scrutiny including inadequate analysis of overall indirect loan portfolio performance and high instances of first payment default, payment deferment and account re-aging.
Another key area involves the relationship between the credit union and dealers. The NCUA said poor dealer management can run the gamut from reliance on the dealer to obtain credit reports to accepting loan payments from dealers and dealer-created down payments through dealer incentives to inflated or fraudulent trade-in or purchase price or continuous overdrafts in dealer reserve accounts.
In that August 2010 NCUA letter, NCUA Chairman Debbie Matz issued several warnings for indirect lending programs including rapid growth that can lead to a material shift in a credit union’s balance sheet composition.
“NCUA has seen seemingly healthy credit unions fail in a matter of months due to indirect lending programs that spun out of control. While there are benefits to a well-run indirect lending program, an improperly managed or loosely controlled program can quickly lead to unintended risk exposure. This can increase credit risk, liquidity risk, transaction risk, compliance risk, and reputation risk,” Matz wrote.
Those risks are likely tied to the fierce competition for shelf space with the dealerships. Many large lenders, including captives have gotten very aggressive with rates, particularly in the prime lending arena, said John Flynn, president/CEO of Open Lending LLC/Lenders Protection, an auto loan underwriter in Austin, Texas. Some lenders are also paying the dealers some aggressive rates and reserves to get the deals.
“We doubt they are making any net yield at all on the super-prime loans. Our view is that for the most part, this loan is typically the only relationship the member has with the credit union so they have to make money on this loan,” Flynn said. “They can’t depend on profits from other products to subsidize the yield.”
One of the key reasons that the indirect funding ratio is much lower that direct is simply that the F&I guy has many choices in their lender network, Flynn said.
“Our belief is that a strong relationship is one of, if not the most important ingredients to having a successful indirect program. The dealers are looking for a lender that is consistent rather than fickle. They also prefer full spectrum lenders,” Flynn said.
According to CUNA, in 2012, approximately 84% were involved in some sort of indirect lending. While it has revenue benefits and can generate membership growth, ultimately the credit union has to stay in and maintain the driver’s seat.
“The credit union must be in control of the program at all times and should not be afraid to terminate the program at any time,” Nevarez said. “Do not hand over the keys to the credit union to your partner, they will do what is in their best interest.”
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