On April 12, 2012, the Consumer Financial Protection Bureau (CFPB) issued CFPB Bulletin 2012-3, a guideline for supervised banks and nonbanks on how to manage their third-party vendors and associated risks. THE CFPB has clearly set forth this document to ensure service provider relationships are compliant with federal law and regulations.
If you are a large bank, credit union, payday lender, mortgage lender or servicer, student lender, large debt collector or buyer, it is your responsibility to make sure your suppliers are knowledgeable about the Federal consumer financial laws and that processes are set to stay in compliance with those laws. Just issuing contracts with third-party vendors that outline monetary liability in the event of a breakdown will not suffice. Proper supplier risk management practices must be in place to avoid consequences for violating any compliance-related responsibilities.
Source One, a leading strategic sourcing consultancy, offers best-in-class Supplier Relationship Management (SRM) services to help your bank or lending firm implement processes to manage third-party vendor risks compliance with CFPB Bulletin 2012-3.Contact us.
CFPB Bulletin 2012-3 emphasizes the need for supervised banks and nonbanks (defined as large insured depository institutions, large insured credit unions and their affiliates, and certain non-depository consumer financial service companies) to manage supplier relationships more closely. Like any business, these banks outsource to third-party vendors to supply products or services due to a lack of resources and/or subject matter expertise, to expand into additional markets, and to perform non-essential functions.
CFPB Bulletin 2012-3 consulting firm, Source One, can help your company implement SRM programs to manage supplier risk and compliance, giving you complete visibility into your supply chain.