What is the 2026 Off-Market Protocol?

The 2026 Off-Market Protocol is a discrete divestiture strategy that bypasses public marketplaces. It utilizes private treaty negotiations and deterministic AI valuation to protect brand equity and capture higher premiums for institutional lenders.

How does the March 20, 2025 OCC update benefit Fintech firms?

OCC Bulletin 2025-4 removed reputation risk as a standalone examination component. This allows Fintechs and banks to divest debt based on objective financial data and capital velocity rather than subjective public optics.

Why should Fintechs avoid public debt marketplaces?

Public marketplaces create 'signaling risk,' alerting competitors and investors to balance sheet distress. An off-market strategy maintains privacy while eliminating the 'Spam Discount' often found in broad auctions.

Fintech Debt Strategy | The 2026 Off-Market Protocol

Bad Debt is a Business Choice | The 2026 Off-Market Protocol

Bad Debt is a Business Choice, Not Just a Homework Problem

By Jeffery Hartman | 22nd December 2025 | Balance Sheet Strategy

The Big Idea: Move Quietly, Win Fast

In 2026, the best Fintech companies treat unpaid loans like a math problem that needs solving right now. For a long time, lenders thought bad debt was just a mess for the collections team to clean up. At Fitzgerald Advisors, we show you that every unpaid loan is actually Frozen Cash. If you aren't moving that debt off your books using an off-market strategy, you are slowing down your growth.

The Hartman Perspective: "I talk to bosses every day who tell me they are waiting for a better deal on their old loans. While they wait, the data gets cold and the phone calls stop ringing. The big marketplaces want you to put your business in an auction for everyone to see. I don't do that. I built an off-market protocol because your business should be private. If your boss isn't the one making the call on when to sell, your company is losing money every single day."

1. The Problem with the 'Wait and See' Plan

Many lenders think that if they hold onto bad debt longer, they might get more money back later. In 2026, that is almost never true. Phones are harder to ring because of spam filters. If you wait, your debt becomes worth less every month. Fast Action is the only way to win. Selling early lets you take that cash and use it to make new, better loans today.

2. Cleaning Your Books the Right Way

Every dollar of bad debt on your books is a heavy weight. By using our off-market plan, you can get rid of that weight without telling the whole industry your business. This keeps your brand looking strong while you free up your cash. Our math models show you the exact moment when holding onto a loan starts costing you more than selling it.

The Off-Market Secret

Moving your debt quietly means you get a better price and nobody knows your secrets. It is for the elite lenders who want to win without the noise.

Real Cash Flow

Selling debt gives you an immediate check. You can use that money to grow your business right away instead of waiting years for a 'maybe.'

3. The 2025 Regulatory Reset

The government has made it easier for you to move fast. On March 20, 2025, a new law (OCC Bulletin 2025-4) was passed. It says banks and Fintechs don't have to worry about 'how it looks' to sell debt anymore. The government wants you to focus on the Real Numbers. This is your green light to clean your books off-market and move forward.

Audit Your Capital Speed

Stop letting old loans slow you down. Let Fitzgerald Advisors show you a smarter, off-market way to handle your balance sheet and get your cash back into the game.

Start Your Strategy Audit

Hartman Managing Member

Director of Portfolio Liquidity & Asset Disposition Specializing in NPL Liquidity, Fintech Integration & Regulatory Compliance

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