What's the Dilly-o with collections & recovery: a buyer's guide for credit unions

The Dilly-o

We'd judge collections software on compliance as much as on recovery.

How we'd size up a vendor

1. Right-party contact - how does the system confirm it is talking to the member, and how does it keep contact times and frequency within limits? We'd ask the vendor to show you how it handles a wrong number.
2. Repayment and resolution - can it capture a payment arrangement, track a promise to pay, and handle hardship and settlement options? Examiners assess whether workouts for members in financial difficulty were reasonable and had proper controls.³ We'd ask the vendor to walk you through a hardship plan, from first contact to a booked arrangement.
3. Communications compliance - does it enforce contact rules, honor opt-out and cease requests, and capture consent and disclosures? We'd ask whether those rules cover every channel the vendor offers, including AI voice and text.
4. Core fit - does the vendor connect to your core today, and who supports that connection? A listing in your core provider's partner program is a better answer than a promise on a sales call.

What changed this year

The same data put the net charge-off ratio at 78 basis points, little changed from the second quarter of 2025.⁴ On the enforcement side, Credit One agreed in February 2026 to pay $9 million in penalties and $1.2 million in investigative costs.⁵ That settled a suit brought by California prosecutors.⁵ The complaint alleged calls continued after consumers asked to stop, or went to wrong numbers; Credit One denied this.⁶ Before you go live, we'd test how any software you consider handles a stop request and a wrong number.

Will it work with your systems?

We'd start your shortlist with what your core and digital banking providers support. On Symitar, REPAY and Eltropy, a text messaging and analytics platform, each joined the Symitar Vendor Integration Program.⁷⁸ We've confirmed that Clutch, maker of the Emma Collections Assistant, is listed for Symitar credit unions in the Jack Henry Fintech Integration Network.^C On the digital banking side, Constant partnered with Alkami and will offer its hardship relief tools to cPort Credit Union in Maine.⁹ Ask each provider which collections vendors it supports, and whether payment plans write back to the loan record.

What other credit unions did

Plaintiffs in a class action against Hughes Federal Credit Union allege its post-repossession notices did not comply with Arizona's Uniform Commercial Code (UCC).¹⁰ Hughes denies liability, and the proposed settlement includes a $7 million cash fund.¹¹¹² Guadalupe Credit Union settled a debt collection class action and denied the allegations.¹³¹⁴

What your examiner will ask

NCUA's 2026 priorities say examiners may review your loss mitigation programs, Allowance for Credit Loss (ACL) methods and charge-off practices.¹⁵ Examiners also check whether modifications and workouts were reasonable and had proper controls and management oversight.³ If you outsource collection, they will assess your third-party risk management too.¹⁶ NCUA says you may be responsible for consumer compliance violations by your agents, so contracts should bind them to the law.¹⁷¹⁸ Its guidance says vendor contracts should address service levels, audit rights, data security and member complaints.¹⁹²⁰

What it costs

We could not find public pricing for the collections platforms themselves, so plan on a written quote. Some agencies tier rates by placement volume.²¹ Experian says flat-rate monthly subscription packages are available for its debt collection software for small collectors.²² NCUA notes that early termination, escape clause and default terms are often negotiable.²³²⁴ Even so, some credit unions accepted buyout penalties believing them standard.²³²⁴ We'd push back on buyout penalties before you sign.

Food for thought

NCUA says credit unions may be responsible for consumer compliance violations by their agents.¹⁸ So before you sign, we'd ask to see the call recordings, the opt-out log and the handoff to a human.