Here’s this week’s compliance question:
We’re a third party vendor (a DBO escrow company). Are we responsible for CMS compliance?
As a vendor, to a certain extent you are. To the extent that you are providing services to financial services organizations, you most likely come under CFPB regulations either through its enforcement authority or its direct supervision.
Companies are going to be looking to their vendors to make sure that vendors are compliant with both federal and state laws in which they are operating. So it does make sense for vendors to take stock of the training of their own staff to make sure that they’re in compliance.
The organizations that vendors market their services to are going to be asking those questions, so it makes sense to be prepared with confident answers.