Are there any regulatory prohibitions against a third party acting as an intermediary (not a collection agency) between a bank and a past due loan customer?
I want to provide guidance to commercial loan customers who may have past due loans to better manage their operations and prevent foreclosure, charge-offs, etc.
It is a common business practice to use intermediaries in collecting past due loans or to pursue past due accounts receivable payments from customers. In most cases, this involves the services of a law firm, who normally start with a letter demanding payment within a specific time frame, usually ten days. This may be enough to prompt the recalcitrant party to pay the outstanding amount or arrange a payment schedule. If payment is not forthcoming than more aggressive steps can be taken within the boundaries of commercial law and with the guidance of a legal firm, like the seizure of assets.
Additional info: This may fall under the Credit Repair Act; however, the service would be focused primarily on improving customers' operations.