It’s been almost two weeks since the CFPB released its proposed rules that will cover short-term and longer-term credit products. It’s been hard for me to have a conversation with anyone in the industry without a majority of the conversation being dominated by THE RULES. This makes sense for several reasons: they have been anticipated for a long time, they are extremely complicated to understand, they may restrict viable financial solutions to consumers in need, and they may radically change the way the industry does business. Granted, when I use the word “may”, it’s only because THE RULES are not final, yet. In my humble opinion, the proposed rules will become effective, and no matter what modifications, if any, are made due to the small business review panel, the final rules will be dramatic and transform the industry.
There is conjecture that the effective date of THE RULES will not be until 2017, which has given some breathing room to some. While that effective date may make sense, postponing action, even if the rules are not final, may be harmful to your operation. There may be some benefits in seeing the finished version of THE RULES to create a plan, but there are definitely benefits in taking some actions now. I’m going to touch on a couple of areas that you should consider as you create your strategy for the future.
Evaluate The Proposed Rules
You should spend some time, as much as necessary, to fully understand the proposed rules. Then, examine how they will affect your existing product mix and profits in the state(s) you operate. I’ve been reviewing and analyzing the rules since they were published and one of best things I have done is to discuss the rules with others to make sure what I am interpreting is similar to what they are interpreting. I suggest having at least one or two additional sets of eyes to review the rules and then get together to discuss what you think. Not only will this lead to clarity, it might also start a productive brainstorming session. Even though THE RULES are not final, it doesn’t hurt to look at several scenarios to determine what your business may look like in 2017.
Evaluate Available Products
Are you currently offering all of the available products in your state? When was the last time you reviewed your competition to see if they have discovered something new? I’m not suggesting that you rush out and add every single product to your mix immediately, but you should have a comprehensive list of available options for you to consider. For each product that you consider, you should model the profit potential, the likelihood of your existing customer base accepting this product, and, importantly, how long it will take to implement this product and work out all of the bugs. If you add a 12-month installment loan as a new product, it is going to take more than a few months to make sure your model works. If you add a product that requires you to change your marketing approach, that may also take some time. That 2017 time horizon isn’t that far away anymore, is it?
What should you NOT do now?
I’ve given you just a couple of things to do, but there are also some things you should not do. First of all, don’t stop providing excellent customer service. Outstanding customer service is the trademark of the industry. You provide customers a needed service that they truly appreciate. Their demand for your products and services has not diminished because of THE RULES. Next, don’t stop becoming lean and efficient in every aspect of your business. Part of this process should include a review of your systems to see if they can accommodate aspects of the proposed rules. Does your loan management system have a built-in CRM? How well does it handle installment loans? Do you have the ability to collect email addresses from your customers and then schedule email campaigns to them? Finally, don’t wait too long to start understanding and acting on the impact of THE RULES. Granted, with a long time horizon and potentially grim prospects, it would be easier to wait and see, but as a successful business owner, is that the behavior that got you to where you are today?
The next two years are going to be challenging, there is no doubt. This is an opportune time to establish strategic partnerships with those that can help you navigate this terrain. Whether it is a consultant with a needed expertise or a business coach to help you gain clarity on your future strategy, we are here to help you succeed. Don’t wait to take your first step.