Fraud Analyst

Overview:
Western Funding (WFI) is in the business of partnering with Dealers to enable them to originate sub-prime auto loans using WFI's Triple Pay program. Dealers follow a signup process to become eligible to use WFI's program and a Master Dealer Servicing Agreement (MDSA) is signed governing the terms of how a dealer and WFI work together.
Given its business model, WFI bears risk from both the dealers and from the deals and therefore should have internal structures designed to address and mitigate these risks to ensure that it is not taking on undue risks. In both cases, Fraud is the primary risk to WFI.
The word "Fraud" is a very sensitive topic. Too often, this word is used loosely. We believe it is important to define it clearly here so that all readers of this document understand precisely what it means in the context of an audit process.
Fraud

• Confirmed misrepresentations by a dealer
  
  • about their business history, legal standing, or ownership structure
  • regarding the facts of any deal submitted for funding consideration
• Confirmed altered documents presented as "proofs" in support of any deal submitted for funding consideration, whether provided by the dealer or the customer.

Dealer Risk

• Initial - it is important for us to know that a dealer is a legitimate business with inventory and active sales operations, operating within the laws of their stated jurisdiction, with ownership who is properly captured and documented under the MDSA. The risk potential here is that we sign up a dealer who does not meet these criteria and receive and fund loans which are not enforceable because they are fraudulently originated. These risks are assessed during the Dealer Sign Up process which is administered by the Dealer Compliance team at the time of signup.
• Ongoing - an otherwise legitimate dealer who is using WFI's program could impart systemic portfolio risk by initiating or enabling fraudulent representations of key facts used to assess the repayment risk of each deal (Customer Identity and Credit, Income/Employment, Residence, Down Payment). This can happen on individual deals (smaller risk) or on all deals (larger risk) and can be perpetrated by dealer employees, by the customers, or a combination of the two.

Deal Risk

• WFI enables dealers to access its scorecard via DealerCenter or DealerTrack to generate advance offers on potential submissions. The creation of an advance offer requires the entry by the dealer of information about the customer, the vehicle and the proposed deal structure.
• The WFI Funding Department is the first line of defense in ensuring that the "facts" of deal are correctly reflected and thus the score, which drives the advance amount, is correct. In addition, there are program parameters that can't be administered by the score but which are administered via the application of policies. The policies are generally determinative of whether a deal can be approved or declined or whether a dealer can receive credit for an input that drives a score variable. The combination of the scorecard (computer enforced) and the policies (team member enforced) are critical to controlling WFI's originations risk. Deals that deviate from WFI's prescribed score or policy guidelines are deemed non-compliant.
• Deals that are non-compliant are likely to perform worse than expected with respect to WFI's profitability targets and additionally, can create challenges in evolving its scorecard by masking the impact of key variables that WFI deems to be predictive of repayment performance.

While both dealer and deal risk are assessed and monitored by existing operational teams within WFI, the nature of their work is transactional and impacted by expectations of a service level. Therefore, WFI is creating a new audit role to serve as an additional level of protection by independently assessing dealer and deal risk, without being impacted by service level expectations, under joint Risk and Management guidance, as described below:
ESSENTIAL DUTIES AND RESPONSIBILITIES (include, but not limited to):
Role Scope:
This role will be responsible for conducting dealer audits on dealers which are flagged based on the triggers outlined below and deal audits based on a specified percentage of funded deals each month. The target allocation of effort by the auditor will be to conduct dealer audits [50%] of their time and deal audits [50%] of their time each month. Audit results will be reported on at least a monthly basis, ideally with weekly updates to the auditor's direct manager, the Director of Risk, and the President.
Dealer Audits:
Audit Triggers:
Any of the following triggers will prompt the Audit Team/Auditor to conduct a dealer audit.

1. New Producing Dealer's 5th deal
2. Early Charge Offs (1 and done)
3. Dealer qualifies for EDC
4. Funding team flags a deal with potential fraud
5. Potential fraud identified during a separate deal audit
6. Volume Spike
7. MSA Audit
8. Management discretion

Audit Process:

1. Dealer is added to the Audit App.
2. Audit App. will randomly assign to an auditor and select the accounts to audit.
3. Depending on the audit trigger the audit size will be 5 -10 deals.
4. All relevant docs are uploaded to the audit app for reference.
5. Auditors will focus on 4 categories while conducting an audit:

Legal and Compliance

1. To ensure contract and legal documents received follow state and regulatory agency laws as well as Western Funding Guidelines.

Primary Identity
2. To ensure all identification and income information provided by the dealer or customer is accurate and legitimate.
Credit
3. To ensure that open and delinquent trade lines follow Western Funding guidelines.
Buy Program
4. To ensure that all information received by the Funding Team is accurate and the dealer was paid based on the accurate risk.
5. Once the audit is completed, it is routed to Originations Audit Supervisor for final review.
Audit Results:

1. Failed Audits resulting in a recommendation for Buyback, Sanction, or both will be sent via email to all appropriate parties.
2. If fraud was not identified and no action is required, no email will be sent.
3. The following actions can be taken if [Fraud] is identified:

• Buyback deals where [Fraud] identified
• Sanction applied at $100 per deal on the next 50 deals
• EDC and/or Holdback payments suspended during sanction period
• Potential termination of MDSA depending on severity

Deal Audits (Compliance):
Audit Triggers:
Prior day funded deals
Audit Process:

1. All High Risk and Very Risk deals are audited.
2. Average Risk deals are audited at 10 per month per Credit Analyst.
3. Auditors will focus on 4 categories while conducting an audit.

Legal and Compliance

1. To ensure that the contract and legal documents received follow state and regulatory agency laws as well as Western Funding Guidelines. All inputs in Underwriting must match that of contract and other legal docs.

Primary Identity
2. To ensure all identification and income information provided by the dealer or customer is accurate and legitimate. All inputs must be accurate based on the information that was received and verified.
Credit
3. To ensure that open and delinquent trade lines follow Western Funding guidelines.
Buy Program
4. To ensure that all inputs were entered accurately based on the information verified by the Funding Team for accurate risk pricing check to the dealer.
5. Once the audit is completed, it is routed to Originations Audit Supervisor for final review.
Audit Results:

• If [Fraud] is identified on an individual deal audit, a full dealer audit will be triggered.
• All HR or VHR deal audits that have failed items but no [Fraud] will be reviewed by the Fraud Analyst.

• Prior month audit results directly impacting a Credit Analysts pay plan will be emailed to them for review on the 1st of the month. Analysts have 48 business hours to dispute any failed items.
• Measurement basis is number of compliant findings as a % of the total opportunities per deal. For example, if there are 20 compliance checks, and the auditor finds 2 non-compliant errors, the compliance calculation will be (20-2)/20 = 90%.

ESSENTIAL KNOWLEDGE, SKILL & LICENSES:

• Bilingual in English and Spanish preferred
• Excellent communications skills
• Able to work in high-pressure environment
• Able to work in a team environment
• Detailed and with excellent organizational skills
• Ability to manage time effectively
• Basic knowledge of computer applications
• Microsoft office (Excel and Outlook)
• Type minimum of 35 wpm
• Web based applications
• 6 months minimum of automotive experience preferred
• 6 months minimum of Skip Tracing experience preferred

What do we offer?

• Medical, Dental, and Vision benefits
• Life Insurance and Long-term disability plans
• Flexible Spending Account
• 401K matching
• Employee Stock Ownership Program in a $18.2 Billion Company, plus company matching
• Wellness Programs
• Metro Tap Card and Metro-link Reimbursement (for Los Angeles, CA employees only)
• Career Path Opportunities
• Discounts on Parks, Museums, Movie Tickets, and Attractions
• Employee Loan Assistance
• Annual Flu Shot
• Paid Vacations Days
• Paid Sick days
• Paid holidays
• HGym (available in our Los Angeles, CA & Dallas, TX office)
• Rental Car Discounts, Dell Member Purchase Program
• UKG Wallet

EDUCATION AND/OR EXPERIENCE:

• High School diploma or equivalent required
• Bachelor's degree from a four-year college or university preferred

ACKNOWLEDGMENTS
We will consider for employment all qualified Applicants, including those with Criminal Histories, in a manner consistent with the requirements of applicable state and local laws, including the City of Los Angeles' Fair Chance Initiative for Hiring Ordinance.
We are an equal opportunity employer and do not unlawfully discriminate in employment. No question on this application is used for the purpose of limiting or excluding any applicant from consideration for employment on a basis prohibited by local, state, or federal law. Equal access to employment, services, and programs is available to all persons. Those applicants requiring reasonable accommodation to the application and/or interview process should notify a representative of the organization.
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