Monthly Archives: November 2016
CFPB Reissues Guidance on Supervised Bank and Non-Bank Relationship with Third-Party Service Providers – Lexology
On October 31, 2016, the Bureau of Consumer Financial Protection (“CFPB”) reissued Bulletin 2012-03 (Service Providers) to clarify certain aspects of the risk management program for service providers. The intention behind the release is to clarify that appropriate risk management can be accomplished through giving flexibility to supervised entities.
CFPB Bulletin 2016-02 – Impact on Title Agents
In this new Bulletin, CFPB again reminds Lenders to secure specific documentation from third party service providers, i.e., tile agents. This is a restatement of the same message sent in a 2012 Bulletin. Title agents should be prepared to receive new requests for copies of written internal policies and procedures that demonstrate their ability to protect the lender’s customer’s NPI.