Upload 2 files

requirements.txt

@@ -1 +1,154 @@
-huggingface_hub==0.22.2
+aiofiles==23.2.1
+aiohappyeyeballs==2.3.4
+aiohttp==3.10.0
+aiosignal==1.3.1
+altair==5.3.0
+anthropic==0.32.0
+anyio==4.4.0
+astrapy==1.4.1
+async-timeout==4.0.3
+attrs==23.2.0
+backoff==2.2.1
+bcrypt==4.2.0
+cachetools==5.4.0
+cassandra-driver==3.29.1
+cassio==0.1.8
+certifi==2024.7.4
+charset-normalizer==3.3.2
+chroma-hnswlib==0.7.3
+click==8.1.7
+clickhouse-connect==0.7.18
+coloredlogs==15.0.1
+contourpy==1.2.1
+cycler==0.12.1
+dataclasses-json==0.6.7
+defusedxml==0.7.1
+Deprecated==1.2.14
+deprecation==2.1.0
+distro==1.9.0
+dnspython==2.6.1
+docopt==0.6.2
+email_validator==2.2.0
+exceptiongroup==1.2.2
+fastapi==0.111.1
+fastapi-cli==0.0.4
+ffmpy==0.4.0
+filelock==3.15.4
+flatbuffers==24.3.25
+fonttools==4.53.1
+frozenlist==1.4.1
+fsspec==2024.6.1
+geomet==0.2.1.post1
+google-auth==2.32.0
+googleapis-common-protos==1.63.2
+gradio==3.50.2
+gradio_client==0.6.1
+grpcio==1.65.2
+h11==0.14.0
+h2==4.1.0
+hpack==4.0.0
+httpcore==1.0.5
+httptools==0.6.1
+httpx==0.27.0
+huggingface-hub==0.24.5
+humanfriendly==10.0
+hyperframe==6.0.1
+idna==3.7
+importlib_metadata==8.0.0
+importlib_resources==6.4.0
+Jinja2==3.1.4
+jiter==0.5.0
+jsonpatch==1.33
+jsonpointer==3.0.0
+jsonschema==4.23.0
+jsonschema-specifications==2023.12.1
+kiwisolver==1.4.5
+kubernetes==30.1.0
+langchain==0.2.11
+langchain-anthropic==0.1.22
+langchain-astradb==0.3.3
+langchain-chroma==0.1.2
+langchain-community==0.2.10
+langchain-core==0.2.27
+langchain-openai==0.1.20
+langchain-text-splitters==0.2.2
+langgraph==0.1.19
+langsmith==0.1.96
+lz4==4.3.3
+markdown-it-py==3.0.0
+MarkupSafe==2.1.5
+marshmallow==3.21.3
+matplotlib==3.9.1
+mdurl==0.1.2
+monotonic==1.6
+mpmath==1.3.0
+multidict==6.0.5
+mypy-extensions==1.0.0
+num2words==0.5.13
+numpy==1.26.4
+oauthlib==3.2.2
+onnxruntime==1.18.1
+openai==1.37.1
+opentelemetry-api==1.26.0
+opentelemetry-exporter-otlp-proto-common==1.26.0
+opentelemetry-exporter-otlp-proto-grpc==1.26.0
+opentelemetry-proto==1.26.0
+opentelemetry-sdk==1.26.0
+opentelemetry-semantic-conventions==0.47b0
+orjson==3.10.6
+overrides==7.7.0
+packaging==24.1
+pandas==2.2.2
+pillow==10.4.0
+posthog==3.5.0
+protobuf==4.25.4
+pulsar-client==3.5.0
+pyasn1==0.6.0
+pyasn1_modules==0.4.0
+pydantic==1.10.13
+pydub==0.25.1
+Pygments==2.18.0
+pymongo==4.8.0
+pyparsing==3.1.2
+PyPika==0.48.9
+pysqlite-binary==0.5.1.3380300
+python-dateutil==2.9.0.post0
+python-dotenv==1.0.1
+python-multipart==0.0.9
+pytz==2024.1
+PyYAML==6.0.1
+referencing==0.35.1
+regex==2024.7.24
+requests==2.32.3
+requests-oauthlib==2.0.0
+rich==13.7.1
+rpds-py==0.19.1
+rsa==4.9
+semantic-version==2.10.0
+shellingham==1.5.4
+six==1.16.0
+sniffio==1.3.1
+SQLAlchemy==2.0.31
+starlette==0.37.2
+sympy==1.13.1
+tenacity==8.5.0
+tiktoken==0.7.0
+tokenizers==0.19.1
+toml==0.10.2
+toolz==0.12.1
+tqdm==4.66.4
+typer==0.12.3
+typing-inspect==0.9.0
+typing_extensions==4.12.2
+tzdata==2024.1
+urllib3==2.2.2
+uuid6==2024.1.12
+uvicorn==0.30.4
+uvloop==0.19.0
+watchfiles==0.22.0
+websocket-client==1.8.0
+websockets==11.0.3
+wrapt==1.16.0
+yarl==1.9.4
+zipp==3.19.2
+zstandard==0.23.0

westlake-policy.txt

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+C. Authorized Party
+To add an Authorized Party to an Account, the Customer must call Westlake Customer Service at 1‐888‐739‐9192 to make the request. Any authorization provided by the Customer verbally and with the
+Customer on the phone is only valid for that same day. Future and ongoing communications to an
+Authorized Party must be provided by the Customer in writing. The written authorization request from
+the Customer must be filed in FileNet and the Account must be documented in the Customer’s
+account.
+As an alternative, a person who can produce a valid power of attorney appointing the person to act as
+attorney‐in‐fact for the Customer may be added to the Account as an Authorized Party, but only if the
+power granted under the power of attorney is broad enough to allow that person to act on behalf of
+the Customer in all matters with respect to the Account. A power of attorney submitted on other than
+an approved Westlake form must be reviewed by the Legal Department before the person may be added as an Authorized Party.
+
+D. Email Communications
+Email communication is not always secure. Emails can be intercepted and email accounts
+impersonated (a.k.a. phishing). Email communication is not a preferred method of communication
+and, in most cases, is not an option. However, if the Customer requests that this be the only method
+of communication, Westlake may elect to communicate via email.
+
+E. Account Access Websites (MyAccount)
+Westlake allows Customers the ability to access their personal and account information through MyAccount.
+All Customers requesting access to the website must submit the following information as authentication for granting ongoing access to MyAccount:
+• Account Number;
+• Last four digits of Social Security Number;
+• Date of Birth.
+In addition to the three items above, the Customer will need to provide an email address and password
+to be used moving forward for ongoing access. Note: The Customer may provide a different email than
+the one on file.
+Once access has been successfully setup for MyAccount, the Customer is able to do the following
+transactions online:
+• View payment history;
+• Change personal information, such as addresses, phone number, and/or email addresses;
+• View current and prior billing statements;
+• Make payments;
+• Requests payoff quotes;
+• Enroll for ACH;
+• Enroll in email notifications;
+• Submit complaints or questions to Customer Service about their Account;
+• Access Servicing related information not regarding the Account.
+
+A. Changing or Correcting a Customer Name
+A Customer can change only his or her own name. A Customer cannot change the name of another
+person on the Account (e.g., a co‐buyer, cosigner). The Customer must submit legible copies of
+supporting documents of a legal change of the Customer’s name. Below are specific examples of
+acceptable supporting documents:
+• Marriage license, in case the customer has recently gotten married;
+• Divorce decree;
+• Social Security card; or
+• Court order documenting the name change.
+If a Customer has requested to correct his/her name, the Customer must submit proof of the new
+name the Customer wishes to use. Acceptable forms of proof are legible copies of government‐issued
+identification. Below are specific examples of acceptable government‐issued identification:
+• Social Security card;
+• Valid and unexpired U.S. passport;
+• Valid and unexpired U.S. military identification card or discharge record (DD‐214);
+• Valid and unexpired State Driver’s License; or
+• Valid and unexpired State Identification card.
+If the Customer’s request to change his/her name involves only rearranging letters in the name or
+changing the way the name is spelled, which would not result in changing more than three (3) letters,
+the request may be accepted and processed without the need to review government‐issued
+identification. However, if the change is more than rearranging letters in the name or changing the
+way the name is spelled resulting in the changing of three (3) or more letters, a government issued
+identification must be obtained to accept and process the request.
+Note: Never rely on copies of any required documentation that are illegible, appear to be altered or
+otherwise appear suspicious, or where there is any other reason to question the authenticity of the
+documents.
+
+B. Change of Customer Social Security Number
+If the Customer requests to change his/her Social Security number, the Customer must submit a legible
+copy of his/her Social Security card. If the Customer’s request to change his/her Social Security number
+involves transposing only two (2) numbers, Westlake may make the correction without submission of the
+Social Security card.
+
+C. Change of Customer Address or Telephone Number
+A Customer may request to change his/her address or telephone number by standard mail, email or
+over the telephone. Westlake must validate the change of address as provided below.
+If Westlake receives a notice from the United States Postal Service (“USPS”), the National Change of Address
+(“NCOA”) service, or other similar service that the Customer’s address has been changed, Westlake must
+note the “new” address in the Customer’s file.
+If Westlake receives the information about a change of address from a third party other than the USPS or
+the NCOA or a similar service, Westlake must note the address in the Customer’s file but should not proceed
+to change the address of record.
+Note: If a Customer changes his/her address to another state, Westlake may need to ensure that the registration and Vehicle certificate of title are reissued in the new state upon the customer’s request.
+See “Change to Vehicle Title” below.
+
+VII. Customer Requests for Account Documents or Information
+The Dodd‐Frank Wall Street Reform and Consumer Protection Act gives the Customer the right to
+request records relating to his/her Account. The right applies to information “in the control or
+possession” of the creditor, and to information “relating to any transaction, series of transactions, or
+to the Account including costs, charges and usage data.”
+Westlake makes some of this information available to the Customer in an electronic form usable by the
+Customer. The Consumer Financial Protection Bureau will prescribe rules that make it clear how a
+creditor is to comply with this new requirement. Until a rule is published, Westlake follows the following
+protocol.
+When a request for information is received from a Customer, Westlake must review its records to gather
+the information requested. If the Customer has requested the information electronically, Westlake may:
+• Provide the information in a password‐protected PDF file to the email address in Westlake’s record
+along with instructions on the hardware and software requirements necessary to retrieve the
+information; or
+• Westlake can burn the PDF file to a CD or copy it to a flash drive, and mail to the Customer’s address
+of record.
+o If a password protected file is used, the password must be communicated to the
+Customer separately by mail to the Customer’s address of record or by phone to the
+phone number of record.
+Westlake will make reasonable efforts to accommodate Customer requests for a different method of
+electronic transmission of the information, if the requested method is feasible for Westlake and at least as secure as the methods described above.
+The following information is excluded from this requirement:
+• Confidential commercial information, including an algorithm used to derive credit scores or
+other risk scores or predictors;
+• Information collected for the purpose of (i) preventing fraud or money laundering, or (ii)
+detecting, or making any report regarding other unlawful or potentially unlawful conduct;
+• Information required to be kept confidential by any other provision of law; and
+• Information that Westlake cannot retrieve in the ordinary course of its business with respect to the
+information requested.
+
+VIII. Account Maintenance A. Request for Automatic Payment
+A Customer may request to enroll in automatic payments at any time. Please refer to the Westlake ACH
+Policy. There is no cost for this service and it is not a requirement or condition of credit. A Customer
+may cancel the enrollment at any time. Westlake accepts enrollments in automatic payments using only its
+approved enrollment forms or web‐based requests made online via MyAccount.
+
+B. Account Payment
+Westlake accepts various forms of payment on Accounts. A Customer may pay Accounts as follows:
+• By standard mail:
+• Personal check;
+• Money order;
+• Certified or Cashier’s check;
+• By phone:
+• Check/Debit card;
+• One‐time ACH withdrawal;
+• By IVR:
+• Check/Debit card;
+• By branch walk‐in (not available in all states and assigned banks only);
+• Web‐based via MyAccount:
+• Check/Debit card;
+• One‐time and recurring ACH withdrawal;
+• Direct transfers to a Westlake bank account:
+• ACH or other electronic transfers;
+• Automatic debits from Customer’s bank account;
+• MoneyGram or other third‐party service that electronically transfers funds to Westlake on
+Customers’ behalf;
+• Wire transfers;
+• Pay Near Me (7‐11) locations.
+If the customer would like to pay using check or money order via Standard US Mail, tell the customer to address the letter to Westlake Financial, PO Box 54807, Los Angeles, California 90054.
+If the customer would like to pay using check or money order via Express Mail, tell the customer to address the letter to Westlake Lockbox Services, Lockbox Number 73082, 3440 Flair Drive, El Monte, CA 91731.
+If the customer is mailing their payment, tell them to ensure that their account number is on either their check or money or order. 
+
+C. Payment Processing
+Payment processing will occur the same business day (excluding federal banking holidays) the
+payment is received; however, if there is a delay in processing the payment, the payment will be
+credited or posted as of the date it was received. Westlake will reverse any late fee assessed because of late
+posting within a reasonable time after Westlake discovers the late posting.
+
+D. Waiving Late Fees
+Upon request of a Customer, Westlake may waive a late fee if any of the following apply:
+• The Customer experienced a loss of income or an unforeseeable expense;
+• The Customer can demonstrate that a billing statement was not received in time to make a
+payment in a timely manner;
+• There was a payment posting issue;
+• Westlake has not waived more than one (1) late payment fee within the prior twelve (12) months,
+unless such late fee was caused by an error made by Westlake.
+Waiver of any late fee for any reason other than those outlined above must be approved by a
+Department Lead, Supervisor, Manager or above in the Servicing Department. Westlake will note the waiver
+in the Customer’s file. The following are the maximum amounts allowed for the waiving of any late
+fees within the same Account:
+• Servicing agent/Compliance specialist: One (1) late payment fee per Account within twelve (12)
+months, unless such late fee was caused by an error made by Westlake;
+• Department Lead: Two (2) late payment fees per Account within twelve (12) months;
+• Department Supervisor: Up to $50.00 per month per Account;
+• Department Manager: Up to $250.00 per month per Account;
+• Compliance Supervisor/Legal Department/Director of Servicing and above: Unlimited.
+When a late fee waiver is requested through a complaint received from the Customer, the Compliance
+Department will evaluate the basis for the complaint. The Compliance Department as a settlement
+may make a decision to waive late fees other than for the reasons listed above. The Compliance
+Department will notate the waiver in the Customer’s file.
+
+E. Waiving Non-sufficient funds Fees
+Upon request of a Customer, Westlake may waive NSF fees if any of the following apply:
+The Customer mailed in a check payment, Westlake did not receive the check in a timely manner and
+requested the customer place a ‘stop payment’, which then returns insufficient funds;
+• The agent entered a wrong bank account number and Westlake will give the customer the benefit of
+the doubt;
+• There was a payment posting issue;
+• Customer is looking to pay off the remaining balance and is asking for NSF to be
+excluded/waived.
+Waiver of any NSF fee for any reason other than those outlined above must be approved by a
+Department Lead, Supervisor, Manager and above in the Servicing Department. Westlake will note the
+waiver in the Customer’s file. The following are the maximum amounts allowed for the waiving of any
+NSF fees within the same Account:.
+• Servicing Agent: One (1) NSF fee per Account within twelve (12) months, unless such NSF fee
+was caused by an error made by Westlake;
+• Assistant Supervisor: Two (2) NSF fees per Account within 12 months;
+• Department Supervisor: Up to $50.00 per month per Account;
+• Department Manager: Up to $250.00 per month per Account;
+• Compliance Supervisor/Legal Department/Director of Servicing and above: Unlimited.
+
+F. Account Payoff
+1. Account Payoff Request
+When Westlake receives a request for a payoff figure from someone other than the Customer or an
+Authorized Party, Westlake must confirm that the request is legitimate and that the Customer initiated it.
+Westlake will consider a request for a payoff figure to be legitimate if all amounts owed to Westlake are paid in
+full (i.e., the account is current) and the payoff is requested in connection with:
+• A refinancing of the Account balance by another financial institution; or
+• A trade‐in transaction involving a licensed motor vehicle dealer.
+The financial institution or dealer must be able to correctly provide all of the following:
+• The Customer’s name;
+- The vehicle’s year and make;
+• The Customer’s Westlake Account number; or
+• The Vehicle Identification Number of the vehicle (last six numbers, at a minimum).
+If Westlake has any question about the legitimacy of the payoff request, the Customer must be contacted to
+confirm the request.
+
+2. Processing of Account Payoff – Before the Scheduled End of Term (“Early Payoff”)
+When Westlake receives an Early Payoff, Westlake must note the following information in the Customer’s file:
+• The date received;
+• The type of funds received (e.g., personal check, business check, certified check/funds, money
+order, EFT, ACH);
+• The source of the funds (e.g., if a business check, the name of the finance
+company/bank/lender/dealer that is the maker of the check);
+• The amount of the Early Payoff received; and
+• Whether the Early Payoff is sufficient to pay off the Account in full.
+Westlake’s Servicing system will automatically waive any small payoff deficiency in the amount of $20 or less.
+Any additional amounts must be manually waived and will require approval by the Department
+Manager.
+When Westlake receives an Early Payoff, Westlake must comply with state security interest release/title
+requirements. To ensure compliance, Westlake has adopted the following practice when processing an Early
+Payoff:
+• If the Early Payoff method remitted was not via certified funds, the title will be released within
+ten (10) business days of payment posting date;
+• If the Early Payoff method remitted was made via certified funds, the title will be queued to be
+released within two (2) business days after the payment posting dates.
+Westlake also complies with state requirements to return the original Contract marked “Paid” or a similar
+requirement to the Customer after a payoff. Westlake satisfies this at the time it releases its security interest.
+Westlake currently stamps all Contracts in all states as “Paid” when returned to the Customer along with the
+title.
+Westlake ensures compliance with state law timing requirements by taking all necessary steps to prepare
+for the release of its security interest and returning the Contract (if required) as soon as possible after
+receipt of an Early Payoff, including retrieving the vehicle title and original Contract, as applicable. For
+example, if the trigger for releasing the security interest is clearing of the Early Payoff funds, the
+Custody Department must obtain the title and Contract during the processing of the Early Payoff funds
+so that the security interest can be released and the Contract returned as soon as the Early Payoff
+funds clear. Westlake will note the Customer’s file when these events occur.
+
+3. Processing of a Scheduled Final Payment to Payoff Account
+When Westlake receives the final payment of a Contract (“Final Payment”), Westlake must determine whether
+the Final Payment is sufficient to pay off the Account in full. Westlake policy is to automatically waive any
+small payoff deficiency in the amount of $20 or less.
+When Westlake receives a Final Payment, Westlake must comply with state security interest release/title
+requirements. To ensure compliance, Westlake has adopted the following practice when processing a Final
+Payment:
+• If the Final Payment method remitted was not via certified funds, the title will be released
+within ten (10) business days of payment posting date;
+• If the Final Payment method remitted was made via certified funds, the title will be queued to
+be released within two (2) business days after the payment posting dates.
+Westlake also complies with state requirements to return the original Contract marked “Paid” or a similar
+requirement to the Customer after a payoff. Westlake satisfies this at the time it releases its security interest.
+Westlake currently stamps all Contracts in all states as “Paid” when returned to the Customer along with the
+title.
+Westlake ensures compliance with state law timing requirements by taking all necessary steps to prepare for
+the release of its security interest and returning the Contract (if required) as soon as possible after
+receipt of a Final Payment, including retrieving the vehicle title and original Contract, as applicable. For
+example, if the trigger for releasing the security interest is clearing of the Final Payment funds, the
+Custody Department must obtain the title and Contract during the processing of the Final Payment
+funds so that the security interest can be released and the Contract returned as soon as the Final
+Payment funds clear. Westlake will note the Customer’s file when these events occur.
+
+G. Account Credit Refunds
+If Westlake receives more than the amount necessary to pay off an Account (i.e., over‐ payment), the overpayment
+will be refunded to the Customer after Westlake investigates the over‐payment to ensure that a
+refund is appropriate. If possible, Westlake will coordinate over‐payment refunds with the release of the
+security interest and transfer of the title. However, Westlake should make the refund no more than twenty
+(20) days from the date it received the overpayment.
+
+B. Change to Vehicle Title
+Westlake Customers may request, from time to time, Westlake’s assistance in updating the content of the vehicle’s
+title. Typical transactions Customers may ask to complete include state changes, name changes, and
+corrections to vehicle information (year, make, model, and odometer).
+In the event the Customer moves to another state, Westlake or the Customer may need to surrender the
+title to the motor vehicles department in the new state so that a new title can be issued. Generally, a
+Customer must obtain a new title in her/his new state of residence before she/he can register the
+vehicle for use in the new state. It is the Customer’s responsibility to ensure that the vehicle is properly
+registered within their respective state’s allotted time requirement. Similarly, Customers seeking to
+update/change their names on titles will need to surrender the prior title to the state’s motor vehicles
+department, and provide any supporting documentation proving the legal change of their name, in
+order for a new title and registration to be issued reflecting the new name.
+Westlake utilizes Dealertrack FDI Collateral Management’s services (a vendor which also serves as the
+custodian for all Westlake titles) to assist in processing these requests for its Customers. “MyTitleSupport”,
+a division of Dealertrack, provides online self‐service support for consumers who elect to update their
+titles for the purpose of completing a state change or updating their names on titles. All Customers
+requesting to complete these transactions must be referred to Mytitlesupport.com or can receive
+assistance with their request by calling 877‐248‐4443. A fee for Mytitlesupport’s services may apply.
+
+A. Vehicle Insurance Coverage
+Westlake monitors Customer accounts to verify that the Customer has the insurance required by the
+Contract. Thirty (30) days prior to the vehicle insurance expiration date, Westlake shall send a notice to the
+Customer’s address on file notifying him/her to provide proof of new insurance. In the event that an
+insurance cancellation notice is received directly from an insurance provider, Westlake will send a
+cancellation notice to the Customer requesting that proof of new insurance be submitted. Although,
+Westlake monitors for insurance and sends notices to Customers, Westlake will not force‐place insurance to secure
+its collateral.
+
+B. Insurance Coverage
+If a vehicle is damaged but repairable, Westlake will work with the Customer and the Customer’s insurance
+company to help arrange for the vehicle to be repaired. After obtaining proof of repair acceptable to
+Westlake, Westlake will provide any endorsement on any insurance company check or other payment instrument
+necessary to permit the Customer to use the insurance payments to pay for the repairs. In some cases,
+Westlake may elect to apply the insurance proceeds to the balance of the Account if the Contract and state
+law permits it to do so. For example, Westlake might elect to apply the insurance proceeds to the Account
+balance where the damage does not impact the safe operation of the vehicle and, in Westlake’s judgment,
+the cost of the repairs exceeds the increase in the vehicle’s value resulting from making them. Westlake will
+inform the Customer of this election before the Customer contracts for the repairs.
+If the vehicle is a total loss, Westlake will apply any insurance proceeds to the unpaid balance of the Account.
+If a deficiency balance remains on the Account, the Customer is informed of their financial
+responsibility under the Contract to continue to make the monthly contractual payments until all
+monies due are paid in full. During any claims process, the Customer is made aware that they should
+continue to make payments as required per their Contract. If the Customer purchased guaranteed
+asset protection (“GAP”) coverage through Knight Management Insurance Services, LLC, Westlake will
+review the GAP coverage per the GAP Agreement signed by the Customer and will waive the remaining
+deficiency balance per the GAP Agreement.
+
+A. Change of Due Date of Monthly Payments
+A Customer may request that Westlake change the due date of her/his monthly payments. A one‐time
+contractual due date change is available for the Customer’s convenience upon verbal, written, or
+online, as long as the qualifications have been met. A new payment due date will be given to better
+suit the Customer’s income and budget schedule.
+The first payment due date after the change must not be more than fifteen (15) days forward from
+the date the Contract was signed by the Customer. A Customer may change the payment due date
+only once over the life of the Contract. Before granting a due date change, the following must be met:
+ At least one (1) full payment must have been posted to the Customer’s Account;
+ A due date change must bring the Customer’s Account current or not more than five (5) days
+delinquent to allow for processing time;
+ The Customer must have paid at least one (1) payment between a due date change and an
+extension;
+ The Customer must request the due date change through self‐service (MyAccount), in writing
+or orally. The Customer consent is required. Once processing is complete, a confirmation letter
+will be sent to the Customer’s address on file;
+ The Customer must be informed that the due date change may result in the assessment of
+additional finance charges. Please reference the Due Date Change Policy for details on the script
+to be used.
+Any additional due date change or other exceptions to the requirements above must be approved in
+accordance with the Westlake Due Date Change Policy.
+
+B. Payment Extensions and Deferrals
+A Customer may request Westlake to defer or extend the due date of a specific payment (“Extension”). An
+Extension moves the due date of a particular payment to a later date. The payment may be past due
+or due now or in the future. Westlake may offer Extensions to help Customers with a record of making timely
+periodic payments. An Extension provides a Customer who has experienced a financial difficulty extra
+time to make the payment.
+For additional details, please refer to Westlake’s Extension Policy. Generally, however, the followingc onditions for required for granting an Extension:
+• The Customer must have made at least four (4) complete payments to qualify for the first
+Extension;
+• The Customer must have made at least four (4) complete payments from the time of the
+previous Extension to qualify for another Extension;
+• If the Account is current (not delinquent), a commitment payment is not required;
+• In a state where an Extension agreement is required, the Account must not be queued for an
+Extension until the Extension agreement is signed by the Customer and returned to Westlake. A
+written extension agreement is required in eight (8) states. Please reference Westlake’s Extension
+policy for details.
+
+C. Change of Other Contract Terms
+In certain circumstances, Westlake and the Customer may agree to modify other terms of a Contract. Below
+are the terms that may be modified without triggering the refinancing requirements under the Truth
+in Lending Act (“TILA”):
+• Reduction of the Annual Percentage Rate (“APR”) with a corresponding change in the payment
+schedule;
+• Change in the payment schedule (so long as the APR does not increase, and the new amount
+financed does not exceed the unpaid balance plus earned finance charge and premiums for the
+continuation of certain insurances);
+• Change in collateral requirements as a result of the Customer’s default or delinquency (so long
+as the APR does not increase, and the new amount financed does not exceed the unpaid balance
+plus earned finance charge and premiums for the continuation of certain insurances);
+• Forgiveness of an amount that is delinquent with a corresponding reduction of the total amount
+owed;
+• Change in the payment schedule to reduce the amount of the scheduled payments with a
+corresponding extension of the term. However, some states limit the term. Therefore, state
+law must be consulted so that the maximum length of a term is not exceeded.
+Note: Westlake will treat any change in the terms of a Contract other than those described above as a
+refinancing that requires new disclosures under TILA. Westlake does not refinance loans.
+
+XVII. Customer Complaints
+Westlake gives all Customer complaints prompt, courteous, and fair attention. Westlake receives direct disputes
+from Customers, and indirect disputes through the CRAs regarding information that Westlake has furnished
+to the CRAs. The Fair Credit Reporting Act (“FCRA”) imposes certain obligations and requirements for
+information Westlake has furnished to the CRAs. Westlake addresses all complaints within specified time frames,
+and also logs all formal complaints escalated to the Compliance Department in the Customer Complaints Log. Please consult Westlake’s Credit Reporting Manual for more details.
+
+A. General Requirements
+Retaking the Vehicle:
+Generally, Westlake is entitled to take possession of a vehicle after default without judicial process if it can
+be done without breaching the peace. Repossession is governed by the Contract, each state’s version
+of the Uniform Commercial Code, any other applicable state law such as retail installment sales
+contract acts applicable to motor vehicles, consumer credit statutes or other laws specifying
+repossession requirements or restrictions.
+In some states, a Customer may be entitled to notice and an opportunity to cure a default before Westlake
+can repossess a vehicle. In other states, a Customer may be entitled to a notice of Westlake’s intent to
+repossess or may have the right to reinstate the Contract after repossession by paying just the past
+due payments and some or all of Westlake’s repossession costs.
+All states permit the Customer to redeem the vehicle after repossession by paying the full balance
+owed to Westlake plus permissible repossession expenses.
+Sale of Vehicle:
+Generally, after a valid and proper repossession, the creditor may sell or dispose of the vehicle in any
+commercially reasonable manner. In most (but not all) states, the creditor may sell the vehicle at a
+public or private sale.
+Westlake is required to send the Customer (and certain other interested parties) a reasonable notice of the
+time and place of a public sale or the time after which a private sale will occur. Westlake will send the notice
+of disposition by first class mail, unless state law requires another mailing method. If Westlake is required
+to send the notice of disposition by another mailing method that requires the Customer to accept and
+sign for the notice, such as registered or certified mail, Westlake will also send a copy of the notice by first
+class mail. Westlake will send the notice at least fifteen (15) full calendar days before the date of the public
+sale or the earliest date a private sale may be held.
+Application of Sale Proceeds:
+Generally, Westlake must apply the proceeds of the sale or other disposition to the
+Customer’s account in the following order:
+��� The reasonable expenses of retaking, holding, preparing for sale, and selling the vehicle;
+• Reasonable attorney’s fees if provided for in the Contract and not prohibited by state law;
+• Satisfaction of the remaining amount due on the Contract; and
+• The satisfaction of any subordinate security interest in the Vehicle, if Westlake receives written notice
+of any such subordinate interest before distribution of the proceeds is completed.
+Westlake must pay the Customer any surplus proceeds. If there is a deficiency, Westlake is generally entitled to
+collect it from the Customer. Westlake must send a written notice of explanation of calculation of surplus or
+deficiency in certain circumstances. Westlake will send this notice by first class mail, unless state law requires
+another mailing method. If, under state law, Westlake has to send the notice by another mailing method
+that requires the Customer to accept and sign for the notice, such as registered or certified mail, Westlake
+will also send a copy by First Class mail.
+
+SALIENT ADDED.
+MyAccount
+MyAccount is an app created by Westlake Financial Services, so customers can manage their accounts directly from their phones or tablets. Westlake MyAccount offers customers the convenience of making a payments and even setting up recurring payments through this application.
+MyAccount customers can register for their account through the application or use existing logins if previously created through the Westlake MyAccount website - myaccount.westlakefinancial.com).
+
+TRADING-IN OR SELLING THEIR CAR
+A customer could ask about trading in or selling their car. First, the customer will want to figure out how much money the customer still owes. The customer can gather this information by asking their lender for the payoff amount on their loan. The payoff amount is how much the customer need to pay to wipe out the balance on their existing auto loan. The figure may differ from the balance listed on their loan statement due to factors like interest calculation, prepayment penalties, and more.
+Then, the customer should use a pricing guide to find the estimated value of their vehicle. This amount may differ depending on whether the customer want to sell their vehicle to a private party or trade it in with a car dealer. Once the customer have their estimated vehicle value, the customer can use the simple formula below to calculate the equity in their car:
+Vehicle Value – Payoff Amount = Vehicle Equity
+If their vehicle equity is a positive number, the customer may be able to sell their car to someone else and make enough to pay off the loan (and potentially put some extra money in their pocket). Negative equity means their vehicle's value isn't high enough to pay off their outstanding loan balance.
+If the customer wish to sell a financed vehicle with negative equity, they will either need to pay off the remaining loan balance out of pocket or roll that amount into a new loan. It's important to proceed with caution with either approach, especially when it comes to new financing. Deciding to go further into debt can have long-term financial consequences.
+When the customer take out a loan to buy a car, the lender is the true owner of the vehicle until the customer pay off the debt. The lender will also place a lien on the vehicle to protect its investment. they will need to pay the loan in full before the lender will release the lien and title—allowing the customer to resell the vehicle to another party.
+If the customer is planning to sell a vehicle that the customer still owe money on, talk to their lender first to find out how to proceed. Each lender has its own process where this type of transaction is concerned. For example, with a bank or credit union, the lender might have the customer bring the buyer into their local branch to pay off the loan balance (either in cash or with financing of their own). If the buyer has agreed to pay the customer more than the payoff balance, they could pay the customer the remaining amount in a separate transaction.
+
+ALREADY MADE A PAYMENT
+Customer states that they had already made a payment, which Westlake has not received or processed. Westlake will investigate why the payment was not received. 
+
+PARTIAL PAYMENT 
+If the customer can only make a partial payment, tell the customer that payments are applied to account balances in the following order: Fees, Interest, Principal, Expenses, Late Charges, Insufficient Fund Fees, Insurance, and Deferred Expenses.
+
+PAYMENT GRACE PERIOD
+If the customer asks about a grace period, apologize to the customer for any confusion. Tell the customer that their contract does not have any grace period. Their account is considered past due at one day late and interest will start to accrue. 
+
+UNABLE TO MAKE A PAYMENT
+In the event a customer is unable to make a payment, our first priority should be to engage in a respectful and understanding dialogue. First, try to secure a date when the customer can make a payment. If you cannot secure a future payment date, ask the customer why they cannot make a payment. Then, thank the customer for their time and say, "I understand. I will escalate this internally and a manager will call you back shortly. Thank you, and goodbye!". The consequences of not making a payment include potentially affecting their credit score.