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Compliance Challenges for Vacation Ownership Financing

Read Time 3 mins | Written by: Ericka Schwarm

Vacation ownership companies have a lot on their plate – sales and marketing, owner services, resort management. Each of these areas is affected by a myriad of laws and regulations, both state and federal. Perhaps, though, the most highly regulated area is loan servicing and debt collection.


The Fair Debt Collection Practices Act, the Fair Credit Reporting Act, Regulation F and numerous other federal and state regulations strictly govern what companies trying to collect debt can and cannot do. Even minor violations of these laws could result in large fines and bad publicity for your company. What’s more, there are ever-changing regulations regarding data security and privacy. There are countless ways to run afoul of the law.

What’s worse, the chances of getting caught if you do are only increasing. According to a January 29 notice on the website of the Consumer Financial Protection Bureau, “we are significantly expanding our enforcement capacity in 2024 to build on our achievements so far. These positions include enforcement attorneys as well as non-attorney positions, including analysts, paralegals, e-litigation support specialists, economists, and more.” There’s also a growing squad of attorneys who specialize in suing creditors who make major or even minor violations of the Federal Debt Collection Act.

That’s why Concord Servicing has designed a proprietary Compliance Management System to maintain consistent compliance with all applicable laws and regulations, including the FDCPA, FCRA, and the TCPA. This system is managed by our in-house counsel. That means that when Concord services your accounts, you can rely on us to be the experts in consumer communications, data safety and security and compliance-related regulation.

As consumers now expect to access services across a myriad of channels, our team ensures that each email, text, online chat message and telephone call contains necessary disclosures and adheres to consumer privacy rules and other guidelines.

Almost every day there is a headline reporting that an organization that has had a data breach compromising their customers’ data. These breaches can lead to fines and bad publicity. One way to decrease the likelihood that you’ll be one of those headlines is a System and Organization Controls (SOC) review. This review proves that an organizations pays attention to crucial details, such as safeguarding customer data from unauthorized access. SOC1 Type 2 examines a service organization's controls over financial reporting. A SOC 2 Type 2 report examines how well a service organization's cybersecurity systems and controls perform over time. What is their operating effectiveness? Do they function as intended? Concord Servicing has been audited and found to be fully compliant.

All merchants that accept credit cards must follow the Payment Card Industry Data Security Standards. The standards are meant to help protect cardholder data, which, in turn, protects you and your customers. Non-compliance can result in hefty penalties and leave you vulnerable to losing your privilege to accept credit cards. Concord maintains a PCI DSS Level 1 Certificate of Compliance from Trustwave Information Security & Compliance. This means that we have designed our network security with industry best practices with respect to firewalls, data encryption, virus protection, system access, intrusion detection and protection.

Of course, many vacation ownership choose to make similar investments on their own. Whether you choose to service your own accounts using Concord’s industry-leading platform, call on Concord’s Blackwell Recovery for collections, or simply have Concord handle all your loan servicing needs, you can rely on us. As a provider of a range of loan servicing solutions that includes primary and subservicing, backup servicing, document custody, loan validation and auditing, and collections, Concord goes above and beyond to support our clients in the way that best meets their needs.

We can help optimize your loan portfolio...

Ericka Schwarm

Ericka is VP of Business Development at Concord. She has deep knowledge of vacation ownership loan servicing and long history in the financial services industry.