Legal and Deficiency Recovery Manager

Legal and Deficiency Recovery Manager Your Title: Legal and Deficiency Recovery Manager Your Location: Remote/Anywhere within the USA You Report To: VP of Operations Your Compensation: Full total compensation package at $130,000 Learn more about our awesome Collections Department About the Opportunity: The Manager, Legal and Deficiency Recovery owns all legal and compliance gates, including eligibility for legal escalation, consumer contact standards, vendor oversight, and outside counsel management. This is a build role creating a structured post charge-off recovery program from scratch, turning currently uncollected balances into meaningful returns. This is not a practicing attorney role external counsel handles legal action. This role leads the compliance framework, ensures all consumer interactions are legally sound, and builds the program with speed and autonomy. What you will do: Your duties include, but are not limited to: Post Charge-Off Recovery Program • Design and own the qualification criteria that determine which accounts with a defiance balance are eligible for legal escalation. Accounts route based on these criteria automatically. Maintain the controlled file, validate that routing is working correctly through periodic audits and spot-checks, and sign off on any changes to thresholds before they take effect. • Monitor the legal escalation pipeline to confirm the right accounts are being worked and the criteria are being applied accurately. Review exceptions flagged by the collections team and maintain the compliance log as the audit trail for the program. • Review and approve all settlement letter content before any mail is sent. Ensure compliance with FDCPA requirements and applicable state law in every state where accounts are located. • Review and approve the deficiency collection contact script and settlement authority structure before they are used with borrowers. Reapprove any material changes. • Own the legal and compliance reporting within the collections KPI package. Prepare the quarterly Board update on the post charge-off program and escalate material issues to leadership promptly. Regulatory and Compliance • Complete FDCPA and UDAAP review of consumer-facing components before launch and provide sign-off. Keep reviews current as regulatory requirements change. • Build and maintain a state-by-state legal viability map for deficiency collections across the portfolio. Keep it current as laws change and communicate updates to the teams that need them. • Ensure all deficiency collection approaches across borrower segments are anchored to loan attributes, not internal product or program classification. Document the ECOA compliance basis before differentiated treatment goes live. • Manage bankruptcy filings across the portfolio • Ensure SCRA compliance for servicemember accounts. • Coordinate responses with compliance on CFPB inquiries, state attorney general matters, and consumer complaints escalated through regulatory channels. • Build and deliver compliance training for post charge-off staff before any live account is worked. Vendor and Outside Counsel Oversight • Vet all third-party collection agencies before any account is placed. Evaluate compliance posture, call recording infrastructure, data security standards, and relevant experience. Ensure contracts include the provisions required to maintain oversight and accountability. • Own the ongoing agency compliance program. Conduct regular call audits, track the consumer complaint log, and manage the performance monitoring and remediation process for agencies that fall below standard. • Oversee third-party BPO partners working post charge-off accounts. Ensure they operate within approved scripts, authority levels, and FDCPA requirements. • Lead outside counsel evaluation and selection for the legal escalation pipeline. Own the relationship: manage account referrals, monitor case outcomes, and track cost against recovery. • Review vendor contracts before execution and confirm required compliance and oversight provisions are in place. Policy, Process, and Cross-Functional Work • Write and maintain all policies and procedures for the post charge-off collections program. Version-control all documents. Communicate changes before implementation. • Manage active collections-related litigation in coordination with outside counsel. Maintain a current litigation log. Report material developments to the VP Servicing and COO. • Identify process gaps that create legal exposure or leave recovery on the table. Bring solutions, not just observations. • Serve as the legal and compliance resource for daily questions from collection agents, team leads, and directors. Provide clear guidance without waiting for outside counsel on routine matters. • Hire and develop direct reports as program volume increases. This role grows into a team leadership position. What you Bring: • 5 or more years of experience in legal operations, compliance management, or collections oversight within consumer lending, auto finance, or a third-party collection agency. • Demonstrated historical career stability • Experience in non-prime or subprime auto lending specifically. The borrower profile, state law environment, and legal tool set are materially different from prime lending or other consumer credit, and this role requires someone who already understands that context. • Working knowledge of FDCPA, UDAAP, and applicable state consumer protection laws as they apply to post charge-off collections. Able to review scripts, letters, and vendor practices for compliance without relying on outside counsel for routine questions. • Experience managing bankruptcy filings across a consumer lending portfolio and handling SCRA compliance for servicemember accounts. • Has managed outside counsel relationships. Knows how to scope work, review billing, hold counsel accountable to timelines, and escalate when representation is not performing. • Has worked in or alongside a deficiency recovery operation. Understands the difference between active collections and deficiency recovery, and how settlement letters, agency placement, and legal escalation work together in practice. • Able to read and interpret collections performance data without needing a data team to validate whether a program is performing. • Bachelor's degree required JD, paralegal certification, or CRCM preferred but not required. Strongly Preferred • Has designed, built, or led a post charge-off deficiency recovery program from the ground up, covering settlement letters, internal contact, agency placement, and legal escalation. • Has managed legal collections activity across multiple states. Knows which states prohibit wage garnishment. Has coordinated with outside counsel on deficiency suits and post-judgment enforcement. • Has built or administered an agency compliance monitoring program. Has exercised a right-to-audit provision. Has terminated a vendor relationship for compliance failure. • Background at a non-prime auto lender or servicer: Consumer Portfolio Services, Westlake Financial, Exeter Finance, CAC Holdings, DriveTime, First Investors, or similar. FHF Benefits... • Great Perks - We offer generous salaries, competitive health and welfare benefits (medical, dental, vision, LTD/STD, Identity theft, paid parental leave and much more), paid vacation, 401(k) match, tuition reimbursement, social activities, monthly lunches, a robust employee recognition and talent development program to enhance your career with us. • Culture - We are believers in maintaining a healthy work-life balance. While we work hard and care deeply about our customers and partners, we want you to have room for your family, friends, and yourself. • Growth - Company growth provides unprecedented career growth. FHF's extraordinary year over year growth in revenue and new markets provides opportunity for you to establish and develop your career growth. We engage each employee to build a career plan that benefits everyone and we have a proven record of investing in you.