We review third party vendors and service providers in accordance with the Consumer Financial Protection Bureau’s and Federal Agencies’ expectations for supervised banks and non-banks, with respect to overseeing their business relationships with service providers in a manner that ensures compliance with Federal consumer financial law.
Conduct thorough due diligence to verify that the service provider understands and is capable of complying with Federal consumer financial law.
Request and review the service provider’s policies, procedures, internal controls, and training materials to ensure that the service provider conducts appropriate training and oversight of employees or agents that have consumer contact or compliance responsibilities.
Review the contract with the service provider for clear expectations about compliance, as well as appropriate and enforceable consequences for violating any compliance-related responsibilities, including engaging in unfair, deceptive, or abusive acts or practices.
Determine if internal controls are established for on-going monitoring to determine whether the service provider is complying with Federal consumer financial law.
Provide report for initiating prompt action to address fully any problems identified through the monitoring process and review in order to facilitate changes needed for compliance.