Loss Mitigation Rep

The Loss Mitigation Representative proactively manages delinquent and at-risk auto loan accounts on behalf of Credit Union of Texas, with the goal of preventing repossession where possible, protecting CUTX's collateral position when not, and resolving bankruptcy, charge-off, and legal-recovery matters in a manner consistent with state and federal law and CUTX member values. The role combines member-facing negotiation, skip tracing, repossession placement and oversight, bankruptcy administration, third-party agency management, and post-charge-off recovery, and uses CUTX-approved AI and analytics tools to prioritize accounts, recommend workout options, and support documentation. The primary objective is to minimize charge-offs, reduce repossession frequency, protect collateral value, and deliver fair, respectful, and compliant member solutions.

• Contact delinquent members to identify hardship causes and negotiate sustainable payment arrangements.
• Analyze member financial situations and recommend appropriate workout options, including extensions, deferments, payment arrangements, and reinstatement plans, within delegated authority.
• Counsel members on the consequences of continued delinquency, including repossession, credit reporting impact, and deficiency exposure.
• Monitor high-risk accounts and intervene prior to repossession assignment where workout is viable.
• Collaborate with internal departments to identify early-warning indicators of potential default and refine prevention strategies.
• Document every negotiation, commitment, and outcome in the system of record to support regulatory compliance and audit defensibility.

• Determine when repossession is necessary based on delinquency status, risk assessment, member cooperation, and SCRA verification.
• Assign repossession orders to approved vendors in compliance with the Texas Debt Collection Act, UCC Article 9, and CUTX policy.
• Verify that all required pre- and post-repossession notices (including right-to-cure and notice of intent to dispose of collateral) have been issued accurately and timely.
• Monitor repossession activity from assignment through recovery, including transport and delivery to the designated storage facility or auction.
• Work with members to redeem repossessed vehicles when appropriate, including processing redemption payoffs and personal property retrieval.
• Coordinate handoff with the Remarketing Specialist for post-recovery disposition, deficiency balance establishment, and final documentation.
• Review and provide input on floor prices and final sale prices of repossessed units in partnership with Remarketing.

• Receive and process all mail, payments, pleadings, and notices on accounts in bankruptcy; properly flag and notate each account in the system of record.
• Evaluate whether to stop automatic payments and deposits, freeze funds, or deny services consistent with the automatic stay and CUTX policy.
• Note important dates of hearings, 341 meetings, and court deadlines for future attendance or response.
• Check for co-borrowers, co-debtors, and joint owners that may be affected by the bankruptcy and ensure appropriate handling of each obligor.
• File Proofs of Claim and Reaffirmation Agreements with proper attachments and recommend legal action for each account where appropriate.
• Review bankruptcy schedules for indicators of fraud or misrepresentation and escalate as required.
• Monitor each bankruptcy account through discharge or dismissal and update credit bureau reporting accordingly.
• Work with attorneys, trustees, and court personnel to resolve bankruptcy issues, maximizing recovery while reducing risk of bankruptcy code violations.

• Perform advanced skip tracing using internal systems, third-party tools, public records, credit bureau data, and other lawful investigative resources.
• Locate members and collateral in support of cure, repossession, or legal action.
• Analyze payment patterns, employment data, and behavioral trends to assess recovery likelihood and prioritize effort.
• Document investigative steps thoroughly to support audit, legal, and regulatory defensibility.

• Work with attorneys and agents to research and file various legal actions, including sequestrations (replevins), J.P. Suits, and foreclosures.
• Handle processes surrounding levies and garnishments, ensuring compliance, accuracy, and timely response.
• Coordinate with internal Legal and external counsel on litigation strategy and recovery actions.

• Assist with the placement and maintenance of third-party collection efforts, ensuring accounts are sent timely and tracked through resolution.
• Monitor agency compliance with applicable SOC 1 / SSAE 18 (legacy SSAE 16 / SAS 70) reporting expectations and CUTX vendor requirements.
• Validate agency invoices and recovery remittances for accuracy and route for processing per policy.
• Support periodic agency performance reviews and contribute to selection and renewal recommendations.

• Perform daily transactions including posting of payments, internal transfers, and account charge-offs.
• Work with members on charged-off accounts to reach satisfactory payment arrangements or settlement agreements within delegated authority.
• Evaluate cost-benefit of repossession versus workout versus settlement and document the rationale for the chosen path.
• Recommend further legal action or recovery effort where appropriate.

• Maintain accurate and up-to-date daily, monthly, and yearly reports for collection audits and examinations.
• Ensure credit bureau reporting is updated on settlements, repossessions, bankruptcies, and charge-offs, and follow up to confirm accuracy.
• Ensure every action on a delinquent, repossessed, bankrupt, or charged-off account is documented in the system of record sufficient to support audit, examination, and litigation review.
• Identify and escalate any potential wrongful repossession, automatic-stay violation, FDCPA concern, or member-harm issue immediately to the Manager of Collections and Compliance.
• Maintain awareness of changes in Texas debt collection law, UCC Article 9, FCRA, FDCPA, CFPB guidance, SCRA, and bankruptcy code, and apply them in day-to-day work.

• Participate in pilots of CUTX-approved AI tools that support loss mitigation, contribute feedback, and adopt approved enhancements.
• Use AI-augmented prioritization, workout recommendation, and skip-tracing analytics under human-in-the-loop review.
• Identify process patterns affecting recovery outcomes and recommend changes to the Manager of Collections.

Outcome

Primary KPI

Reporting Cadence

Target / Direction

Delinquent accounts are cured or restructured before repossession where feasible.

Workout Cure Rate — percent of assigned delinquent accounts cured or placed on a sustainable workout prior to repossession assignment.

Monthly

▲ [Target — confirm with VP, Collections]

Repossession is used only when other options are exhausted, reducing portfolio loss.

Repossession Avoidance Rate — percent of high-risk accounts resolved without repossession.

Monthly

▲ [Target]

Net charge-off exposure on the assigned portfolio is minimized.

Net Charge-Off Ratio on assigned portfolio.

Monthly

▼ [Target]

Bankruptcy accounts are handled timely and accurately, protecting CUTX's claim position.

Proof of Claim / Reaffirmation Timeliness — percent filed within required deadlines.

Monthly

▲ ≥ 98%

Post-charge-off recovery is maximized.

Post-Charge-Off Recovery Dollars vs. plan.

Monthly

▲ [Target]

Every file is audit-ready and litigation-defensible.

Audit-Ready File Rate — percent of files passing internal compliance review without material exception.

Quarterly

▲ ≥ 98%

AI-augmented recommendations affecting members are reviewed by the role holder before action.

Human-in-the-Loop Review Rate on AI Recommendations — percent of AI-recommended workout, prioritization, or skip outputs reviewed and either accepted, adjusted, or escalated before member action.

Monthly

▲ 100%

• High school diploma or general education degree (GED) required.
• Associate or bachelor's degree preferred.

• Minimum one to two (1–2) years of related collections, recovery, or loss mitigation experience required; two to four (2–4) years preferred.
• Direct experience with repossession placement, skip tracing, and bankruptcy administration strongly preferred.
• Prior experience with collateral protection insurance and third-party agency management preferred.
• Prior credit union or community bank experience preferred.
• Prior experience using AI- or analytics-driven prioritization or recommendation tools preferred.
• Bilingual English / Spanish preferred.

• Valid Texas driver's license preferred (occasional field travel may be required).

• Working knowledge of credit union lending programs, policies, and default enforcement clauses.
• Thorough knowledge of collections, servicing, foreclosure, and bankruptcy procedures and the underlying legal requirements.
• Working knowledge of the Texas Debt Collection Act, UCC Article 9, FCRA, FDCPA, CFPB guidance, SCRA, and the U.S. Bankruptcy Code as applied at CUTX.
• Advanced negotiation, conflict-resolution, and de-escalation skills with high emotional intelligence.
• Strong investigative and skip-tracing capability.
• Ability to assess financial risk and make sound recovery decisions with limited supervision.
• Strong documentation discipline and regulatory awareness; ability to maintain audit-ready files.
• Strong written and verbal communication, including the ability to draft compliant member-facing notices and correspondence.
• Proficiency with Microsoft Office (Word, Excel, Outlook, Teams) and the ability to learn CUTX's loan servicing and collections systems.
• Strong analytic, organizational, and time-management skills with the ability to manage a high-volume queue and competing deadlines.
• Ability to work a flexible schedule, including evenings and weekends as business needs require.

Competency

Proficiency Level

Why This Matters in This Role

AI Literacy

Intermediate

The role uses AI-augmented prioritization, workout recommendation, and skip-tracing tools (Tier 2) and is accountable for human-in-the-loop review on every member-impacting output.

Member Centricity

Intermediate

The role engages members during financial hardship; tone, accuracy, and procedural fairness directly affect CUTX's reputation and member outcomes.

Negotiation & Influence

Advanced

Curing delinquency, structuring workouts, and settling charged-off balances require advanced negotiation, judgment, and de-escalation skill.

Risk Awareness

Advanced

Repossession, bankruptcy, levies, and litigation are high-regulatory-exposure activities; the role must identify and escalate compliance issues in real time.

Operational Discipline

Advanced

Every file must be audit-ready and litigation-defensible; documentation gaps create direct legal, examination, and reputational exposure.

Compliance Orientation

Advanced

Texas Debt Collection Act, UCC Article 9, FCRA, FDCPA, CFPB guidance, SCRA, and bankruptcy code are applied in daily work; mistakes have direct member and legal impact.

Communication

Intermediate

The role drafts member notices and communicates with members, attorneys, trustees, court personnel, vendors, and internal partners across multiple channels.

The following workflows are AI-augmented in this role. The Loss Mitigation Representative is expected to work fluently within these workflows, exercise sound judgment over AI outputs, and follow all applicable controls.

• AI-assisted account prioritization — AI ranks delinquent accounts by recovery likelihood, risk, and recommended treatment path.
• AI-assisted workout recommendation — AI suggests candidate workout options (extension, deferment, payment arrangement, reinstatement) based on member financial profile and historical outcomes.
• AI-assisted skip-tracing analytics — AI synthesizes internal and approved third-party data to surface likely contact paths and collateral locations.
• Document extraction and triage — AI extracts structured fields from bankruptcy notices, court filings, agency remittances, and member correspondence to populate the system of record.
• AI-assisted drafting of internal call notes and case summaries (non-member-facing) using approved tools.

This role operates in AI Tier 2 for its principal AI-augmented workflows (see Appendix A). The Loss Mitigation Representative retains accountability for any decision, communication, or member/employee-impacting action influenced by AI output, consistent with the CUTX Generative AI Usage Policy §3.4.

The Loss Mitigation Representative is required to:

• Apply human-in-the-loop review on every AI-recommended workout option, prioritization output, skip-tracing lead, and any member-facing communication before action is taken.
• Stop reliance on AI output and escalate immediately if the output appears inaccurate, biased, non-compliant, or outside the role's documented scope (Generative AI Usage Policy §3.5).
• Refrain from entering member non-public personal information (NPI), confidential CUTX information, or material non-public information into any AI tool not explicitly approved for that data classification.
• Complete all required AI training within thirty (30) days of hire and maintain currency on annual refreshers.

The role is approved to use the following AI tools in performing essential functions (subject to the Generative AI Usage Policy and any tool-specific guidance issued by the AI Council):

• CUTX-approved internal AI assistants (e.g., Sam) for general productivity and approved knowledge tasks.
• Microsoft Copilot for office productivity (drafting, summarization, spreadsheet support).
• CUTX-approved AI-augmented prioritization and workout recommendation tools deployed within the collections platform.
• CUTX-approved skip-tracing and investigative analytics tools.

Use of AI tools outside this list requires prior approval from the role's department leader and the AI Council, per the Generative AI Usage Policy §4.

In addition to the prohibited uses defined in the Generative AI Usage Policy §3.6, the following are specifically prohibited in this role:

• Using AI output as the sole basis for any adverse member action, including a decision to repossess, deny a workout, deny redemption, refuse a settlement, or report adverse credit information.
• Entering member NPI (full account numbers, Social Security numbers, member loan documents, bankruptcy schedules) into any AI tool not explicitly approved for that data classification.
• Using consumer AI tools to draft member-facing legal notices (right-to-cure, notice of intent to dispose of collateral, deficiency notice, bankruptcy filings); these documents must be drafted from approved templates and reviewed per existing procedure.
• Using AI to make or simulate independent legal judgments in bankruptcy, litigation, or repossession matters in lieu of guidance from CUTX Legal or external counsel.

The Loss Mitigation Representative is responsible for all enterprise compliance obligations applicable to a CUTX team member, including BSA/AML, OFAC, USA PATRIOT Act/CIP/CDD, GLBA and the Safeguards Rule, Fair Lending laws (ECOA/Reg B, Fair Housing Act), UDAAP, Information Security and Acceptable Use, and the CUTX Code of Conduct.

The Loss Mitigation Representative is responsible for the CUTX Generative AI Usage Policy (TRAIGA / HB 149-aligned), the CUTX AI Playbook (including Tier 2 obligations applicable to this role), and Texas Responsible Artificial Intelligence Governance Act (TRAIGA / HB 149) requirements applicable to the role.

• Texas Business and Commerce Code, Chapter 9 (Uniform Commercial Code, Article 9) — Disposition of Collateral.
• Texas Debt Collection Act and Texas Finance Code provisions applicable to collection, repossession, redemption, and deficiency.
• S. Bankruptcy Code, including the automatic stay, Proof of Claim, Reaffirmation Agreement, discharge, and dismissal procedures.
• Federal Fair Credit Reporting Act (FCRA), including credit reporting accuracy on delinquent, repossessed, bankrupt, and charged-off accounts.
• Federal Fair Debt Collection Practices Act (FDCPA) standards as applied at CUTX (CUTX adheres to FDCPA standards as a matter of policy).
• Consumer Financial Protection Bureau (CFPB) guidance applicable to debt collection and loss mitigation.
• Servicemembers Civil Relief Act (SCRA) — verification of military status before repossession or legal action and adherence to applicable protections.
• CUTX Collections Policy, Repossession Procedures, Bankruptcy Procedures, and Charge-Off Procedures.

This role is performed primarily on-site at the CUTX Corporate Office in a standard office environment, with occasional field travel within the Dallas–Fort Worth metropolitan area to support recovery, court appearances, or vendor coordination. The schedule is flexible and may include evenings and weekends as business needs require. Essential physical activities include the ability to remain stationary at a workstation for extended periods; operate a computer, telephone, and standard office equipment; communicate clearly by phone, email, and in person with members, attorneys, court personnel, vendors, and internal partners; and review printed and electronic documents for accuracy. The role involves frequent talking and hearing, repetitive use of hands and fingers, and occasional standing, walking, reaching, and lifting up to 10 pounds. Reasonable accommodations will be made to enable individuals with disabilities to perform the essential functions of this role, consistent with the Americans with Disabilities Act and CUTX policy.

The responsibilities contained within this job description remain compliant with the Bank Secrecy Act/Anti-Money Laundering, Office of Foreign Assets Control, and USA PATRIOT Act as they apply to the duties of the position.

This job description is intended to describe the general nature and level of work being performed by individuals assigned to this position. It is not intended to be an exhaustive list of all responsibilities, duties, and skills required, and CUTX reserves the right to modify, add to, or remove duties at any time as business needs require.

Employment with CUTX is at-will. This job description does not constitute an employment contract.