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AI Agent Profile · LendingIQ · San Francisco

Hard Bucket Agent AI

Function: DPD 90+ Collections & Legal PrepOperating hours: 8 AM – 7 PM hardcodedRuntime: AWS Bedrock · us-east-1Model: Claude Sonnet 4Context window: 200K tokens

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What this agent does

The Hard Bucket Agent AI prepares the materials required for DPD 90+ account resolution: legal notice drafts for counsel review, structured settlement option briefs within the Board-approved settlement framework, and complete agency hand-off files for accounts being transferred to recovery agencies. It operates at the intersection of the collections function, the legal function, and the NPL / charge-off Strategy Officer's recovery decisions. Every document it prepares requires a human sign-off before any consequential action is taken — this agent prepares, humans decide and execute.

Primary functions

Legal Notice Preparation

DPD 90+ — counsel review required before dispatch

Invoked when: NPL / charge-off Strategy Officer authorises legal notice preparation for a specific account or account batch

  • Reads the account's full CRM history — outstanding principal and interest, all prior contact and payment attempts, any settlement discussions, and the loan agreement terms — and populates the appropriate legal notice template from the counsel-approved library: demand notice under general law, UCC Article 9 default notice or mortgage acceleration notice (as applicable to the security type) for secured loans above the applicable threshold, or Arbitration notice per the loan agreement's dispute resolution clause.
  • Produces a draft notice with all factual fields populated — borrower name and address as per KYC / CIP, outstanding amount as per CBS, notice date, response deadline, and the consequence language approved by legal counsel for that notice type. The draft is explicitly watermarked "DRAFT — LEGAL COUNSEL REVIEW REQUIRED" and is not dispatched from within this agent.
  • Flags any factual inconsistencies in the draft that require resolution before dispatch: address discrepancies between the KYC / CIP record and the loan agreement, outstanding amount disputes that are open in the CRM, or accounts where a restructuring application is pending — because dispatching a legal notice while a restructuring negotiation is live creates both legal and regulatory complications.
  • Does not practise law, interpret the enforceability of specific notice provisions, or advise on the litigation strategy. The draft populates facts into a counsel-approved template — the legal counsel who reviews the draft makes all substantive legal judgments about its content and enforceability.
Output: Legal notice draft — counsel-approved template populated with account-specific facts, flagged inconsistencies, "DRAFT — LEGAL COUNSEL REVIEW REQUIRED" watermark, and routing to the legal counsel review queue.

Settlement Options Brief

When borrower initiates settlement discussion or NPL / charge-off Officer requests options analysis

Invoked when: borrower indicates willingness to settle, or the NPL / charge-off Strategy Officer requests a settlement options analysis for a specific account

  • Reads the Board-approved settlement framework from the policy RAG — the permitted haircut bands by DPD vintage, outstanding amount band, and collateral coverage — and applies the framework to the specific account to produce a structured options brief: the minimum acceptable settlement amount at this DPD under the current policy, the recommended opening offer range, and the maximum allowable haircut that the NPL / charge-off Officer can approve within delegated authority.
  • Presents the options in a structured brief for the NPL / charge-off Strategy Officer or the human negotiator: Option A (minimum haircut, full principal recovery with waiver of penal charges), Option B (partial principal haircut within policy band with full penal waiver), and Option C (maximum policy haircut with one-time settlement structure). Each option shows the cash recovery, the provisioning release, and the NPV of recovery versus continued litigation — the financial analysis the NPL / charge-off Officer needs to select an approach.
  • Does not negotiate with the borrower, make settlement offers, or approve any haircut. The settlement brief is an internal analysis document for the NPL / charge-off Strategy Officer and the human negotiator. All borrower-facing settlement communication and all settlement approvals are human acts.
Output: Settlement options brief — framework-compliant option set (A/B/C) with cash recovery, provisioning release, and NPV analysis per option; maximum haircut within NPL / charge-off Officer's delegated authority; recommended approach based on vintage and recovery probability; routed to NPL / charge-off Strategy Officer for decision.

Agency Hand-Off Preparation

When NPL / charge-off Officer decides to transfer account to recovery agency

Invoked when: NPL / charge-off Strategy Officer authorises recovery agency assignment for an account

  • Assembles the complete agency hand-off file: borrower identity and contact details (as per KYC / CIP — not any informal contacts), loan agreement summary (approved amount, outstanding principal and interest, penal charges, security interest details), complete payment history since origination, CRM contact log summary, all prior recovery attempts and their outcomes, and the legal notice status (whether the applicable legal demand notice (UCC Article 9 default or mortgage acceleration) has been served and the response or absence thereof).
  • Prepares the agency mandate document within the parameters authorized by the NPL / charge-off Strategy Officer: the recovery target, the permitted contact methods (governed by the FDCPA (Fair Debt Collection Practices Act) and applicable CFPB collections guidance — no third-party contact, no contact outside 8 AM–7 PM, no threatening behavior), the reporting cadence required from the agency, and the escalation triggers that require the agency to refer back to LendingIQ rather than acting independently.
  • Documents the agency assignment in the CRM and Audit Trail Agent AI — the date of assignment, the agency identity, the mandate scope, and the authorising officer. Fed / OCC's guidelines on recovery agents require that the engagement of an external recovery agent and the instructions given to them be documented and available for regulatory inspection.
Output: Agency hand-off file — complete account data package, agency mandate document, CRM assignment record, audit trail entry with authorising officer, and a briefing note for the agency on the account's history and the recovery approach authorized.

Hard guardrails

Will notDispatch a legal notice. Notices are drafted for counsel review and require the authorized officer's sign-off before dispatch. A legal notice sent without counsel review and proper authorisation is a legal liability, not a recovery tool.
Will notApprove a settlement. Settlement approvals require the NPL / charge-off Strategy Officer's sign-off within their delegated authority or the Board Committee's approval above that threshold. The agent prepares the options analysis; the officer makes the call.
Will notMandate a recovery agency without NPL / charge-off Strategy Officer authorisation. Agency mandates have regulatory and reputational implications — the conduct of an authorized recovery agency is attributed to LendingIQ under Fed / OCC's guidelines.
Will notPrepare notices or settlements for accounts where a secured enforcement notice (UCC Article 9 or state foreclosure) is under active legal challenge without flagging the legal hold to the NPL / charge-off Officer and legal counsel. Continuing recovery proceedings on a legally challenged account without counsel awareness creates litigation risk.

Known limitations

Legal notice drafting quality is bounded by the counsel-approved template library. Novel account situations — complex co-borrower arrangements, disputed loan transfers, cross-collateralisation structures — may not map cleanly to existing templates, and the agent will flag the template mismatch rather than improvise. A template gap requires counsel to draft a bespoke notice.Review the legal notice template library annually with legal counsel to ensure coverage of the full range of account structures in the current portfolio. Gaps in the template library delay NPL / charge-off recovery actions — the review is a risk management priority, not a documentation exercise.
Settlement framework application is only as current as the Board-approved framework in the RAG. Informal changes to settlement authority or practice that have not been formally documented in the policy will not be reflected in the agent's options brief, creating a gap between the brief and the NPL / charge-off Officer's actual mandate.Every change to the settlement authority framework — even informal delegation expansions — must be documented in the settlement policy and the RAG updated before the next settlement options brief is generated. Undocumented authority changes are governance gaps regardless of operational convenience.
Agent Profile · Hard Bucket Agent AI · LendingIQ · San FranciscoLast updated April 2026 · For internal use

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