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Stricter standards and increased scrutiny by the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau (CFPB), as well as the Federal Deposit Insurance Corporation (FDIC) and the Federal Financial Institutions Examination Council (FFIEC), mean financial institutions now have the same responsibilities for in-house and out-of-house services.
While the regulations don’t spell out specific requirements in each area, such as what sort of due diligence a servicer should do, they make it clear that servicers must oversee and control every operation that can affect a customer. To ensure that vendors comply with the regulations, we recommend that financial institutions/servicers follow these steps:
Using these practices will protect both you and the customer.