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The Consumer Financial Protection Bureau

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Overview This document describes the manner in which Vendor Oversight assigns tiers to Pacific Union Financial (“PUF” or the “Firm”) vendors and manages vendors accordingly to facilitate due diligence, maintenance and compliance with Firm, state, and Federal requirements. Background The Consumer Financial Protection Bureau (“CFPB”) is tasked with writing and enforcing rules for financial entities to protect consumers from unfair, deceptive or otherwise harmful practices by such entities. A major area of focus for the CFPB is a robust and effective oversight of a financial institution’s third-party providers (vendors) to ensure consumers are not exposed to unnecessary risk of financial or personal harm. The CFPB has not issued specific rules outlining how a financial institution must oversee its vendors; however, they have provided guidelines which outline the areas that such institutions should consider in their oversight program. Among these, “establishing internal controls and on-going monitoring to determine whether the service provider is complying with Federal consumer financial law” is specifically stated as an expectation of the CFPB for financial institutions towards their third-party providers. Procedure Vendor Oversight has developed and maintains a robust third-party oversight program to efficiently and effectively source, vet, onboard and continually evaluate the performance of PUF third-party providers. As part of this process, each vendor is assigned

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