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  • Review state and federal laws to confirm such fees may be charged;
  • Review debt agreements to determine whether such fees are authorized by the contract;
  • Review internal and vendor policies and procedures on phone pay fees;
  • Review account disclosures to ensure information regarding phone pay fees is included;
  • Incorporate phone pay issues in regular monitoring or audits;
  • Review consumer complaints regarding phone pay fees;
  • Perform regular reviews of third party vendors as to their practices;
  • Review employee incentive programs to see if there are incentives to steer borrowers to certain payment types or to avoid disclosures; and
  • Review corrective action program to address any violations and to reimburse members, when appropriate.

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