On April 13, 2012, the CFPB authored a benign looking guidance bulletin known as CFPB Bulletin 2012-03 to amplify their expectation that supervised banks and nonbanks should have an effective process for managing the risks of service provider relationships. Now, there are third party vetting companies that have established themselves under the guise of helping supervised banks and nonbanks comply with intent of the bulletin. Unfortunately, it seems that some of these vetting companies are only designed to create a “pay-to-play” system that benefits the supervised banks and nonbanks without any real benefit towards compliance or the expectation of the CFPB bulletin.
NAILTA has asked its members for input on this important issue because the vetting company growth only impacts independent title agents. Vetting companies acknowledge excluding all direct operations from the vetting requirements, thus NAILTA members are squarely in the crosshairs of this potential new movement. Read our white paper to find out more about NAILTA’s position on third party vetting companies and the CFPB bulletin.