By now you should have your compliance team in place, your policies and procedures finalized, and your complaint management system humming. But if your organization is a typical collection agency, debt buyer, or collection law firm, you know you have one final hurdle to overcome on your CFPB readiness path: Vendor and service provider management.

A new whitepaper from Ontario Systems seeks to provide clarity on this topic. What follows is an excerpt from the whitepaper, available for free download on our site.

#3: Take Inventory

You can’t manage what you don’t know. Create a list of every service provider with which you have a
business relationship, and which supports your core collection business in any way. Remember to include
any business that touches, transmits, houses, or has access to consumer financial information
on this list. You may refer to this document as your Service Provider Inventory. An Excel spreadsheet
would work well for this purpose.

Next, for each service provider on your Service Provider Inventory document, identify the name and
contact information for the primary contact person within the service provider’s organization who
can answer questions about the contract, bills and invoices, or the types of services generally available.
Also include the name and contact information for the primary, 24/7 contact person, who can
respond to a crisis, emergency or data breach.

Don’t forget to include a column indicating whether a written contract is in place, the effective date of
the contract, and the contract renewal date.

Finally, create columns you will complete at a later date with the following headings:

• CFPB Contract Provisions
• On-site visit required
• On-site visit date
• Compliance training
• Compliance training date
• Receipt of policies and procedures
• Receipt of internal controls
• Receipt of survey
• Receipt of training materials
• Complaint and litigation review

Be sure to maintain this document in your document management system and include a date on the
document indicating when it was last updated and by whom.

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