Here’s how our informal poll played out:
The poll was by no means scientific, but these rough results, while perhaps unsurprising, speak volumes about the uncertainty organizations experience in complying with CFPB regulations and readying themselves for audits.
And it’s those 37% who really concern me. Because if you can confidently place your organization in the “No” category, at least you’re aware of the gaps in your CMS. Saying “I don’t know” is tantamount to having no formal CMS in place at all. From the perspective of the CFPB and your capital providers, if you didn’t document what happened, it didn’t happen.
If you can’t prove what’s happening, where does that leave your organization when you need to demonstrate compliance to a lender, bank or regulator?
Consider that Question 0. To determine the CFPB-readiness of your CMS, take a look at Questions 1–4:
Coming up, we’ll explore how Compli can address all these questions to form the backbone of your CMS. For now, I encourage you to watch our archived webinar, Demystifying Your Compliance Program: What Your Financial Partners Are Looking For.