SERVICE PROVIDER OVERSIGHT SIX CRITERIA

  • Review arrangements, agreements, or contracts exist with vendors and third parties related to mortgage products or servicing.
    • Are changes planned for third party practices as a result of the new rules?
    • Will third party service providers deliver compliant application technology releases and/or fully tested process updates in time for the effective dates?
  • Determine changes have been made or need to be made to the above arrangements, agreements, or contracts to ensure that service providers comply with new regulations and all legal obligations.
  • Audit complaints reviewed regarding vendor activity for compliance and process concerns.
    • How frequently is this complaint data received?
  • Evaluate training procedures received and reviewed for third parties related to regulatory requirements.
  • Determine training provided for any third party service providers.
  • Assess contracts with any third parties related to mortgage activities.
    • Has their implementation plan been discussed and evaluated?
    • Does the financial institution have a back-up plan should the vendor not fully implement the necessary changes prior to the effective dates?