The first step to passing a CFPB regulatory audit is understanding the Bureau's expectations for vendor management. This means understanding the CFPB's guidance on third-party relationships, and what the Bureau expects from vendors in terms of risk management and oversight.
Develop a comprehensive vendor management program: A comprehensive vendor management program should include a detailed vendor selection process, ongoing vendor monitoring, and a plan for addressing any issues or deficiencies that come up. The program should also include clear policies and procedures for managing vendor risks.
Conduct thorough due diligence on vendors: Before engaging a vendor, financial institutions should conduct thorough due diligence to ensure the vendor has the expertise and experience to provide the services required. This includes reviewing the vendor's financial stability, track record, and references.
Make sure you have a contract management process in place: Contracts should spell out what services are being provided, what the expectations are, and what happens if things don't work out. Financial institutions should also have a contract management process in place to ensure ongoing compliance with the terms of the contract.
Monitor vendors regularly: Financial institutions should continuously monitor vendors to ensure they meet the terms of their contract and provide satisfactory services. This includes regular reviews of vendor performance and on-site inspections when necessary.
Have a process in place to address issues and deficiencies: Financial institutions should have a process in place to address any issues or deficiencies that arise with vendors. This includes a plan for addressing vendor noncompliance and terminating relationships when necessary.
Implement a complaint management process: Financial institutions should have a complaint management process in place to ensure that complaints are handled in a timely and effective manner. This includes a process for reporting complaints to the appropriate parties and conducting investigations when necessary.
Maintain proper documentation: Financial institutions should maintain proper documentation to demonstrate compliance with vendor management regulations. This includes maintaining records of due diligence, monitoring, and complaint management activities.
Train employees on vendor management: Financial institutions should train their employees on vendor management regulations and best practices. This includes training on the CFPB's supervisory guidance on third-party relationships, as well as training on the institution's own vendor management policies and procedures.
Review and update vendor management policies and procedures regularly: Financial institutions should regularly review and update their vendor management policies and procedures to ensure they remain compliant with current regulations and best practices. This includes regular risk assessments to identify potential vulnerabilities and taking steps to address any identified risks.
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