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TEKS Solutions

Guide

BHPH Collections Best Practices

Operating practices for buy-here-pay-here collections: cadence by delinquency stage, channels, documentation and Regulation F guardrails, with the 2026 data.

Published
Updated
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10 min read
By
TEKS Solutions operations team
Man in a coat walking between rows of parked cars on a lot, reading from a folder, in low golden light
In this guide

Key takeaways

  • BHPH portfolios sit where delinquency is highest: 16.1% of Q2 2026 auto loan originations went to borrowers under 620 and 5.49% of all auto balances were 90 or more days late, per the Federal Reserve Bank of New York.
  • The first thirty days are where accounts are saved. Experian measured 2.39% of auto loans 30 days delinquent against 0.90% at 60 days in Q2 2026 — its own account-level measure, not directly comparable with the New York Fed's share of balances above — and most late accounts either cure or roll before day 60, so contact decides which.
  • Cadence, channels and documentation should be defined by delinquency stage and enforced in the dialer and the DMS, not left to each collector's memory.
  • Regulation F's operating standards — seven attempts in seven days, 8 a.m. to 9 p.m. in the customer's local time, cease requests honored, an opt-out in every text or email — are the safe floor for a first-party program whatever its legal classification.
  • An outsourced team is only as good as the scripts, aging-bucket procedures and system access it receives in onboarding. Give it the same playbook you would give a new hire, in writing.

Buy-here-pay-here dealerships depend on consistent payment activity across a portfolio of customers who, by design, did not qualify for conventional financing. Collections is not an afterthought to the sale; it is the business model. That makes the quality of the follow-up — its cadence, its tone, its documentation and its compliance — the difference between a portfolio that performs and one that quietly bleeds through charge-offs.

Whether the work happens in the dealership office or through an outsourced team, the principles are the same: clear procedures by delinquency stage, a consistent contact cadence, every attempt documented in the DMS, and guardrails that protect the customer relationship and the dealer. What follows is the operating playbook, with the federal and industry data that explains why each piece matters in 2026.

Why BHPH collections is different

A BHPH customer is typically a subprime borrower on a used vehicle with a short term and a weekly or biweekly payment schedule. Experian's Q2 2026 State of the Automotive Finance Market data, as reported by Auto Remarketing, puts the average used-vehicle loan across the whole market at $27,852 with a $542 monthly payment at an 11.19% APR. BHPH terms are usually shorter and the rates higher, which means the payment is a large share of the customer's take-home pay and a missed paycheck shows up as a missed payment within days.

The macro picture is not getting easier. The Federal Reserve Bank of New York's Q2 2026 Household Debt and Credit report shows $34.0 billion of the quarter's $210.8 billion in auto originations — 16.1% — going to borrowers with credit scores below 620, with the median score on new auto loans down seven points in the quarter. Across all auto balances, 5.49% were 90 or more days delinquent and the flow into serious delinquency was 3.00%, above the 2.93% of a year earlier. A BHPH dealer's portfolio is concentrated in exactly the segment those numbers describe.

The relationship is also different. The dealer is the lender, so the customer's next vehicle, their referrals and their willingness to answer the phone all depend on how the collections conversation feels. Repossession is a real remedy but an expensive one — the goal of the cadence is to keep the customer paying, not to recover the car.

By the numbers

16.1%

Source 1

of new auto loan volume went to borrowers under 620

2026 Q2 · Federal Reserve Bank of New York · Checked 2026-09-14

2.39%

Source 2

of auto loans were 30 days delinquent

2026 Q2 · Experian · Checked 2026-09-14

207,800

Source 3

debt collection complaints received by the CFPB in 2024

Calendar 2024 · Consumer Financial Protection Bureau · Checked 2026-09-14

  1. 1.Federal Reserve Bank of New York, Quarterly Report on Household Debt and Credit, 2026 Q2. Checked 2026-09-14.
  2. 2.Experian, State of the Automotive Finance Market (reported by Auto Remarketing), 2026 Q2. Checked 2026-09-14.
  3. 3.Consumer Financial Protection Bureau, Fair Debt Collection Practices Act Annual Report 2025, Calendar 2024. Checked 2026-09-14.

Structured follow-up cadence by stage

Accounts need defined contact schedules tied to delinquency stage, with the Regulation F frequency presumption — no more than seven attempts per debt in seven consecutive days, and none for seven days after a conversation — treated as a ceiling rather than a target. A cadence that looks like the one below keeps attempts front-loaded where they cure accounts and documented where they protect the dealer. For the lender-wide view from the first missed payment to charge-off, see The Auto Loan Collection Process, Stage by Stage.

  • Before the due date: a courtesy reminder by the customer's preferred channel, especially on the first three payments, when habits are formed and payment-method problems surface.
  • Days 1 to 3 past due: one friendly contact to confirm the payment is coming and remove obstacles (a card that failed, a paycheck that moved). Most cures happen here.
  • Days 4 to 15: a defined sequence of calls and texts across different times of day within the 8 a.m. to 9 p.m. window, each attempt logged, with a promise-to-pay captured and a follow-up date set the moment one is made.
  • Days 16 to 30: escalation to a senior collector or the finance manager, a payment-arrangement conversation, and an insurance and contact-information check on the account.
  • Days 31 and beyond: the dealer's policy governs — arrangement, extension, or the repossession review — but every decision should be traceable to notes that show what was attempted and when.
  • Every promise to pay gets a follow-up on the agreed date. A kept-promise rate is the single best early indicator of whether the cadence is working.

Multi-channel communication

Calls remain central, but many customers who will not answer an unknown number will read a text. SMS and email reminders reach them, reduce inbound confusion about due dates, and create a written record. Two rules travel with those channels. First, every electronic message must include what Regulation F §1006.6(e) calls a clear and conspicuous statement describing a reasonable and simple method to opt out — and an opt-out, once received, must be honored across the whole program, not just the channel it arrived on. Second, the customer's stated channel preference belongs in the account record so every agent sees it.

Time-of-day rules apply to texts as much as calls: a payment reminder at 10 p.m. in the customer's time zone is a complaint waiting to happen. Set the sending window in the system, not in a memo. What a voicemail, text or email may actually say is covered in Voicemail, Text and Email Under Regulation F.

Documentation and account notes

Every interaction should produce a note that a manager can read in ten seconds: who was contacted (right party or not), what channel, what was discussed, any arrangement made, the next follow-up date and who owns it. Notes are how a manager supervises without listening to every call, and they are the dealer's evidence if a customer disputes what happened.

The CFPB's 2025 FDCPA annual report — roughly 207,800 debt collection complaints received in 2024 — shows what poor records cost the industry. The single most common complaint issue was an attempt to collect a debt the consumer said was not owed; within that group, 60 percent said the debt was not theirs and 28 percent attributed it to identity theft. Among complaints about false statements, 91 percent concerned collecting the wrong amount. Those are failures of account data before they are failures of conduct — and they are far less likely on a portfolio where the balance, the customer's identity and every contact are recorded in one system of record. The data side of that problem is the subject of Wrong-Party Contact: The Data Problem Behind the Most Complained-About Issue in Collections.

Compliance guardrails built into the process

Regulation F prescribes rules for debt collectors as the FDCPA defines them, and whether a dealer's own collections operation — or an outsourced team working under the dealer's name — falls inside that definition depends on how the work is structured. The statutory definition at 15 U.S.C. § 1692a(6) excludes a creditor's own officers and employees collecting in the creditor's name; it says nothing that automatically extends that exclusion to a vendor. That classification is a question for the dealer's counsel, and state law such as Texas Finance Code chapter 392 may apply on its own terms.

The operational answer is to build the federal standards into the process regardless of classification, because each of them is cheap to enforce in software and expensive to violate: attempt caps and cool-off periods configured in the dialer; the 8 a.m. to 9 p.m. window checked against the customer's local time, not the dealer's; cease requests flagged on the account on receipt; opt-out language templated into every text and email; no workplace contact where the employer prohibits it; and no direct contact with a customer known to be represented by counsel. TEKS runs every collections program to these standards, and the collections support page lists them.

Metrics that matter

Measure the behaviors that produce cures, not just the cures. Right-party contact rate tells you whether the phone numbers on file are real. Promise-to-pay kept rate tells you whether the conversation is producing commitments the customer can keep. The 30-to-60-day roll rate tells you whether early-stage attempts are happening. Cure rate by stage and charge-off rate tell you the result. Note completeness — the share of attempts with a usable note — tells you whether any of the above can be trusted.

Benchmarks for these figures vary by portfolio, term structure and customer base, which is why TEKS does not publish generic performance percentages. Your own numbers come out of your own data; the point of the cadence is to make them move in the right direction and to be able to prove it.

Working with an outsourced collections support team

An outsourced team performs exactly as well as the playbook it is handed. Before production, give it what you would give a new collector on day one, in writing, and confirm it can work inside your DMS rather than from a spreadsheet outside it. Dedicated agents who work in your system produce notes your managers can supervise; a shared pool working from an export produces reconciliation work. Whether to hand the work off at all is the subject of when a dealership should outsource collections; how to choose a BPO partner covers the questions to settle before price.

  • Scripts and tone guidance by stage, in English and Spanish, including what the team may and may not promise.
  • Aging-bucket procedures: attempts per day and week, channel order, escalation triggers and hand-off points to your staff.
  • Payment-arrangement authority: what the team may set up on its own, what needs a manager, and how arrangements are recorded.
  • System access and note standards: fields to complete, codes to use, and how promises to pay are scheduled for follow-up.
  • Compliance settings: the frequency and time-of-day rules, cease-request handling, opt-out text, and the dispute-escalation path.
  • Reporting cadence: daily activity in the first weeks, then a standing weekly review of the metrics above.

How TEKS supports BHPH collections

TEKS provides first-party collections support for BHPH dealerships with bilingual agents dedicated to one client, working inside the dealer's DMS on the dealer's scripts, from the Monterrey metropolitan area on U.S. Central hours. The team documents every attempt, promise and outcome in your system, runs to Regulation F operating standards, and reports daily through launch. The BHPH dealership page describes a typical program, how dealerships use nearshore BPO shows where collections sits among the other functions a dealership hands off, and a discovery call defines scope, portfolio characteristics and the first aging bucket to hand off.

Frequently asked questions

How often can a BHPH collector call a customer?
Regulation F presumes compliance when a debt collector places no more than seven call attempts about a particular debt in seven consecutive days and does not call within seven days after having a telephone conversation about that debt (12 CFR §1006.14(b)(2)). Calls and texts before 8 a.m. or after 9 p.m. in the customer's local time are presumed inconvenient. Treat the seven-in-seven presumption as a ceiling and front-load attempts in the first days past due, where most accounts cure.
What should a BHPH collections account note include?
Who was reached (right party or not), the channel, the date and time, what was discussed, any payment arrangement or promise to pay with its date, the next follow-up date, and the agent's identifier. The note should be entered in the dealer's DMS or servicing system, not in a separate spreadsheet, so managers and any outsourced team see the same record.
Which delinquency stage deserves the most attention?
The first thirty days. Experian measured 2.39% of auto loans 30 days delinquent against 0.90% at 60 days in Q2 2026 — an account-level measure, not directly comparable with the New York Fed's share of balances 90 or more days late — so most late accounts either cure or roll forward before day 60. Whether an account leaves the 30-day bucket by curing or by rolling is largely decided by whether anyone reached the customer in those thirty days.
Does Regulation F apply to a BHPH dealer collecting its own accounts?
Regulation F governs debt collectors as the FDCPA defines them, and that definition excludes a creditor's own officers and employees collecting in the creditor's name. Whether an outsourced team working under the dealer's name is covered depends on how the engagement is structured and is a question for the dealer's counsel; state law, such as Texas Finance Code chapter 392, may apply separately. Running the program to Regulation F's operating standards regardless is the safe practice.
What should a BHPH dealer give an outsourced collections team before it starts?
Scripts and tone guidance by stage in English and Spanish, aging-bucket procedures with attempt counts and escalation triggers, payment-arrangement authority limits, DMS access with note standards, the compliance settings for frequency, time of day, cease requests and opt-outs, and an agreed reporting cadence. A team that receives this in writing before production performs like a trained hire; one that does not performs like a temp.

Sources

  1. Federal Reserve Bank of New York, Quarterly Report on Household Debt and Credit, 2026:Q2 — originations by credit score, 90+ day delinquency share, serious-delinquency flow. Checked 2026-09-11.
  2. Experian, State of the Automotive Finance Market, Q2 2026 (via Auto Remarketing) — used-vehicle loan averages and 30/60-day delinquency rates, an account-level measure not directly comparable with the New York Fed's share of balances. Checked 2026-09-11.
  3. Consumer Financial Protection Bureau, Fair Debt Collection Practices Act Annual Report 2025 — 2024 complaint volume and issue breakdown. Checked 2026-09-11.
  4. Consumer Financial Protection Bureau, Regulation F, 12 CFR §1006.14 (call frequency) — Checked 2026-09-11.
  5. Consumer Financial Protection Bureau, Regulation F, 12 CFR §1006.6 (communications, cease requests, opt-out) — Checked 2026-09-11.
  6. 15 U.S.C. § 1692a(6), definition of debt collector (Legal Information Institute) — Checked 2026-09-11.
  7. Texas Finance Code, Chapter 392 — Debt Collection — Checked 2026-09-10.

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