Author: sufyan

VPCS Awards EPCVIP Compliance Certification

VP Compliance Services Vendor Certification program is an extensive review and audit of lead gen vendors. A VPCS Certified Vendor is a vendor a lender can trust when looking to purchase leads.

VP Compliance Services is pleased to announce EPCVIP has passed required elements of our Lead Gen Compliance Certification Program.

The Lead Gen Compliance Certification Review examined the following areas (listed below) and found EPCVIP to be operating a compliant organization as of the date of the review and passed our background review.

Please consider EPCVIP for any future lead gen services.

For any questions regarding our Vendor Certification Program please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz. The elements of the certification review EPCVIP passed are listed below:

VPCS Lead Gen Certification	Description	Comments
Date Certified	Date vendor passed the certification audit	Re-audited yearly

Certifications & Accreditations	Description	Comments
Online Lenders Accreditation	Detailed examination of lenders policies and procedures	Current

Liens, Actions, Fines, Investigations	Description	Comments
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses	Description	Comments
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Agreement Review – Client	Description	Comments
Vendor	Examined for required elements of agreements	Passed

Policy and Procedure Review	Description	Comments
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)	Description	Comments
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training	Description	Comments
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed

Vendor Review	Description	Comments
Ongoing Monitoring (reporting, audits, monitoring, reviews)	Reviewed audit frequency and findings	Passed
On Boarding (Questionnaire, Contract Review, Background checks, References)	Policy Exists Reviewed audits and frequency	Passed

Vendor Agreement	Reviewed agreements of TPPPs and ODFIs	Passed

Compliance Management Program	Description	Comments
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program, system to manage, and inability to edit	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search	Description	Comments
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

September 7, 2017

VPCS Awards Fast 1K Loans Compliance Certification

VP Compliance Services Vendor Certification program is an extensive review and audit of lead gen vendors. A VPCS Certified Vendor is a vendor a lender can trust when looking to purchase leads.

VP Compliance Services is pleased to announce Fast 1K Loans has passed required elements of our Lead Gen Compliance Certification Program.

The Lead Gen Compliance Certification Review examined the following areas (listed below) and found Fast 1K Loans to be operating a compliant organization as of the date of the review and passed our background review.

Please consider Fast 1K Loans for any future lead gen services.

For any questions regarding our Vendor Certification Program please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz. The elements of the certification review Fast 1K Loans passed are listed below:

VPCS Lead Gen Certification	Description	Comments
Date Certified	Date vendor passed the certification audit	Re-audited yearly

Certifications & Accreditations	Description	Comments
Online Lenders Accreditation	Detailed examination of lenders policies and procedures	Current

Liens, Actions, Fines, Investigations	Description	Comments
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses	Description	Comments
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Agreement Review – Client	Description	Comments
Vendor	Examined for required elements of agreements	Passed

Policy and Procedure Review	Description	Comments
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)	Description	Comments
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training	Description	Comments
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed

Vendor Review	Description	Comments
Ongoing Monitoring (reporting, audits, monitoring, reviews)	Reviewed audit frequency and findings	Passed
On Boarding (Questionnaire, Contract Review, Background checks, References)	Policy Exists Reviewed audits and frequency	Passed

Vendor Agreement	Reviewed agreements of TPPPs and ODFIs	Passed

Compliance Management Program	Description	Comments
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program, system to manage, and inability to edit	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search	Description	Comments
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

September 7, 2017

VPCS Awards 24/7LoanPros Compliance Certification

VP Compliance Services Vendor Certification program is an extensive review and audit of lead gen vendors. A VPCS Certified Vendor is a vendor a lender can trust when looking to purchase leads.

VP Compliance Services is pleased to announce 24/7LoanPros has passed required elements of our Lead Gen Compliance Certification Program.

The Lead Gen Compliance Certification Review examined the following areas (listed below) and found 24/7LoanPros to be operating a compliant organization as of the date of the review and passed our background review.

Please consider 24/7LoanPros for any future lead gen services.

For any questions regarding our Vendor Certification Program please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz. The elements of the certification review 24/7LoanPros passed are listed below:

VPCS Lead Gen Certification	Description	Comments
Date Certified	Date vendor passed the certification audit	Re-audited yearly

Certifications & Accreditations	Description	Comments
Online Lenders Accreditation	Detailed examination of lenders policies and procedures	Current

Liens, Actions, Fines, Investigations	Description	Comments
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses	Description	Comments
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Agreement Review – Client	Description	Comments
Vendor	Examined for required elements of agreements	Passed

Policy and Procedure Review	Description	Comments
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)	Description	Comments
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training	Description	Comments
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed

Vendor Review	Description	Comments
Ongoing Monitoring (reporting, audits, monitoring, reviews)	Reviewed audit frequency and findings	Passed
On Boarding (Questionnaire, Contract Review, Background checks, References)	Policy Exists Reviewed audits and frequency	Passed

Vendor Agreement	Reviewed agreements of TPPPs and ODFIs	Passed

Compliance Management Program	Description	Comments
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program, system to manage, and inability to edit	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search	Description	Comments
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

September 7, 2017

VPCS Awards Viking Payment Processor Compliance Certification

Irvine, CA (May 03, 2016) VP Compliance Services (VPCS) is proud to announce Viking Billing Services has met the requirements of the VPCS Payment Processor Vendor Certification Program.

The VPCS Vendor Certification Program is a detailed review of vendors operational controls; policies, procedures, training, internal monitoring, data management and security. It also is a review of a vendors background (fees, fines, judgments, liens, BK, regulatory actions, and more). Details on the VPCS Vender Compliance Certification Program can be found on the VPCS website at www.vpcs.biz.

Rick Wittwer, General Partner of VPCS stated, A lender can rely on a VPCS Certified Vendor as having operational controls in place to effectively provide services to their clients. A VPCS Certified vendor will also have passed a background review related to its operating history. VPCS Compliance Certified Vendor should be considered when a lender is looking for payment processing services and when considering a new vendor relationship. Through our investigation and review, Viking Billing Services is a well managed and compliant payment processor.

John OShea, President of Viking Billing Services, said We are very pleased to be recognized as a customer-centric and compliant leader in our field.

About VP Compliance Services

VP Compliance Services (VPCS) is a leading provider of compliance and operational services to the on-line lending industry (state licensed and tribal). Our service offerings support a broad spectrum of credit-related financial services including federal regulatory compliance, program operations, lender audit programs, lender risk assessments, compliance training, complaint management, vendor reviews, vendor certification and temporary staffing of compliance and information security personnel. For more information please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz.

About Viking Billing Services

In business since 1969, Viking is a first-rate provider of ACH and RCC payment processing. Viking Billing Services is headquartered in Minneapolis, MN and operates on a national basis. A member of the Third Party Payment Processor Association and an affiliate member of NACHA (Upper Midwest), we leverage state-of-the-art analytics and customer-facing technology to deliver compliance driven results. For more information please contact John OShea at (952) 944-7575 or joshea@vikingservice.com

The elements of the certification passed are listed below:

VPCS Call Center Certification
Date Certified	Date vendor passed the certification audit	Re-audited yearly
04/15/2016	04/12/2016	Yes

Certifications & Accreditations
American Collectors Association	Review of Policies and Procedures	Current

Liens, Actions, Fines, Investigations
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Policy and Procedure Review
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed
Compliance Training	Review of adequacy and frequency of training	Passed

Compliance Management Program
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program & system to manage	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

May 1, 2016

VPCS Awards Viking Call Center Compliance Certification

Irvine, CA (April 29, 2016) VP Compliance Services (VPCS) is proud to announce Viking Client Services has met the requirements of the VPCS Call Center Vendor Certification Program.

Rick Wittwer, General Partner of VPCS stated, A lender can rely on a VPCS Certified Vendor as having operational controls in place to effectively provide services to their clients. A VPCS Certified vendor will also have passed a background review related to its operating history. A VPCS Compliance Certified Vendor should be considered when a lender is looking to outsource call center services and when considering a new vendor relationship. Through our investigation and review, Viking Client Services is a well managed, compliant, and results driven call center business.

John OShea, President of Viking Client Services, said We are very pleased to be recognized as a customer-centric and compliant leader in our field.

About VP Compliance Services

About Viking Client Services

In business since 1969, Viking is a first-rate provider of billing, collections, insurance subrogation and consumer loan services. Viking Client Services is headquartered in Minneapolis, MN and operates on a national basis. Fully licensed, bonded and insured, we leverage state-of-the-art analytics and customer-facing technology to deliver compliance driven results. For more information please contact John OShea at (952) 944-7575 or joshea@vikingservice.com

The elements of the certification passed are listed below:

VPCS Call Center Certification
Date Certified	Date vendor passed the certification audit	Re-audited yearly
04/15/2016	04/12/2016	Yes

Certifications & Accreditations
American Collectors Association	Review of Policies and Procedures	Current

Liens, Actions, Fines, Investigations
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Policy and Procedure Review
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed
Compliance Training	Review of adequacy and frequency of training	Passed

Compliance Management Program
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program & system to manage	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

May 1, 2016

VPCS Awards First Credit Services Compliance Certification

VP Compliance Services Vendor Certification program is an extensive review and audit of vendors and debt buyers. A VPCS Certified Vendor is a vendor a lender can trust when looking to purchase leads.

VP Compliance Services is pleased to announce that First Credit Services has passed required elements of our Call Center Compliance Certification Program.

The Call Center Compliance Certification Review examined the following areas (listed below) and found First Credit Services to be operating a compliant organization as of the date of the review and passed our background review.

Please consider First Credit Services for any call center services.

For any questions regarding our Vendor Certification Program please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz. The elements of the certification review First Credit Services passed are listed below:

VPCS Call Center Certification
Date Certified	Date vendor passed the certification audit	Re-audited yearly
04/15/2016	04/12/2016	Yes

Certifications & Accreditations
American Collectors Association	Review of Policies and Procedures	Current

Liens, Actions, Fines, Investigations
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Policy and Procedure Review
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed
Compliance Training	Review of adequacy and frequency of training	Passed

Compliance Management Program
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program & system to manage	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

April 19, 2016

3rd Party Vendor Management Services

Comprehensive Third Party Vendor Oversight

Consumers are at a real disadvantage because they do not get to choose the service providers they deal with the financial institution does, said CFPB Director Richard Cordray.

Consumers must not be hurt by unfair, deceptive, or abusive practices of service providers. Banks and nonbanks must manage these relationships carefully and can be held accountable if they break the law. CFPB

To satisfy Regulators, your third party oversight program must be comprehensive. What are the elements of a comprehensive third party oversight program?

Development of the Underpinnings

On-boarding

What are the elements of a Prospective Vendor Questionnaire? Which policies and procedures should you require? What kind of Background Check should you perform? Should you examine the vendors training program? What about their regulatory complaints? Anything else?

Underwriting

Underwriting relates to the logic or grading system you use to evaluate a prospective Vendors questionnaire, policies, background check results, types and quantity of regulatory complaints, and more.

Ongoing Audit Elements

For your existing vendors, ongoing audits are a requirement. This way, you will be able to demonstrate to regulators that your ongoing vendor monitoring is comprehensive and regular.

What should be included in your audit? Should it differ by vendor type? How frequent should I perform? How should I evaluate the audit results? What should I do if the vendor fails an audit?

Policy

Now that you have completed you onboarding elements, underwriting rules and the composition and frequency of you ongoing audits, its time to write your 3^rd Party Vendor Management Policy. What should it include?

..

April 18, 2016
Regulatory Compliance Policies & Procedures
Online Storefront Auto MSBA Commercial

Policies and Procedures describe a company’s operating practices and how they adhere to consumer protection laws. They are active and live documents that are expected to change as a company finds defects in their operations.

Any change to a company’s practice covered policy or procedure must first be reviewed by a compliance committee and if agreed updated through the Change Management Policy instructions. Regulators will inspect your documents to insure lenders and servicers are following this process.

VP Compliance Services develops its clients policies and procedures to meet regulators expectations and train clients on how to operationalize and audit them.

New or mature lender or servicer? We can start anywhere!
- Complete Policy & Procedure Development
- Review and Update Your Policies
- Audit Your Policies and Make Recommendations
- CMS Document Development 1^st Request from CFPB
April 16, 2016

VPCS Awards TheCashResource Compliance Certification

VP Compliance Services Vendor Certification program is an extensive review and audit of vendors and debt buyers. A VPCS Certified Vendor is a vendor a lender can trust when looking to purchase leads.

VP Compliance Services is pleased to announce TheCashResource has passed required elements of our Call Center Compliance Certification Program.

The Lead Gen Compliance Certification Review examined the following areas (listed below) and found TheCashResource to be operating a compliant organization as of the date of the review and passed our background review.

Please consider TheCashResource for any future lead gen services.

For any questions regarding our Vendor Certification Program please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz. The elements of the certification review TheCashResource passed are listed below:

VPCS Lead Gen Certification	Description	Comments
Date Certified	Date vendor passed the certification audit	Re-audited yearly

Certifications & Accreditations	Description	Comments
Online Lenders Accreditation	Detailed examination of lenders policies and procedures	Current

Liens, Actions, Fines, Investigations	Description	Comments
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses	Description	Comments
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Agreement Review – Client	Description	Comments
Vendor	Examined for required elements of agreements	Passed

Policy and Procedure Review	Description	Comments
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)	Description	Comments
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training	Description	Comments
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed

Vendor Review	Description	Comments
Ongoing Monitoring (reporting, audits, monitoring, reviews)	Reviewed audit frequency and findings	Passed
On Boarding (Questionnaire, Contract Review, Background checks, References)	Policy Exists Reviewed audits and frequency	Passed

Vendor Agreement	Reviewed agreements of TPPPs and ODFIs	Passed

Compliance Management Program	Description	Comments
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program, system to manage, and inability to edit	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search	Description	Comments
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

September 5, 2015

VPCS Awards NeedRapidCash Compliance Certification

VP Compliance Services Vendor Certification program is an extensive review and audit of vendors and debt buyers. A VPCS Certified Vendor is a vendor a lender can trust when looking to purchase leads.

VP Compliance Services is pleased to announce NeedRapidCash has passed required elements of our Call Center Compliance Certification Program.

The Lead Gen Compliance Certification Review examined the following areas (listed below) and found NeedRapidCash to be operating a compliant organization as of the date of the review and passed our background review.

Please consider NeedRapidCash for any future lead gen services.

For any questions regarding our Vendor Certification Program please contact Rick Wittwer at (877) 350-9933 X5 or wrw@vpcs.biz. The elements of the certification review NeedRapidCash passed are listed below:

VPCS Lead Gen Certification	Description	Comments
Date Certified	Date vendor passed the certification audit	Re-audited yearly

Certifications & Accreditations	Description	Comments
Online Lenders Accreditation	Detailed examination of lenders policies and procedures	Current

Liens, Actions, Fines, Investigations	Description	Comments
Company Background Check	Background check of company and associated companies	Passed
Principal Owners Background Check	Background check of principals	Passed

Required Licenses	Description	Comments
Corporate Registration	Review of state and federal corporate registrations	Current
State Registrations & Bonds	Review of state registrations and bonds	Complete and current
Collections License Review	All required licences reviewed	Complete and current

Agreement Review – Client	Description	Comments
Vendor	Examined for required elements of agreements	Passed

Policy and Procedure Review	Description	Comments
Identity Authentication	Policy Exists Procedure(s) Exists	Passed
GLBA	Policy Exists Procedure(s) Exists	Passed
Privacy	Policy Exists Procedure(s) Exists	Passed
Record Retention	Policy Exists Procedure(s) Exists	Passed
SCRA / MLA	Policy Exists Procedure(s) Exists	Passed
UDAAP	Policy Exists Procedure(s) Exists	Passed
Vendor Management	Policy Exists Procedure(s) Exists	Passed
TCPA	Policy Exists Procedure(s) Exists	Passed

Information Security (GLBA)	Description	Comments
PCI Scan	Performed on all IP addresses	Passed
Written Security Program	Program Policy Exists	Passed
Information Encryption used when transferring data	Program Policy Exists	Passed
Network Monitoring	Vendor in place	Passed
Firewalls installed	Reviewed firewall technology and vendor	Passed
Default passwords and Security Parameters updated	Policy Exists Procedure(s) Exists	Passed
Protection against system attacks	Technology exists	Adequate practice of testing
Restricted access to Sensitive Information	Policy Exists Procedure(s) Exists	Passed
Secure development of system and applications	Policy Exists	Passed
Audits	Reviewed audit schedule and results	Passed
Physical Security	Policy Exists	Reviewed audits – passed
Clean Desk Policy	Policy Exists reviewed audit	Passed
Facility Access Monitoring	Policy Exists reviewed audit and logs	Passed

Training	Description	Comments
FDCPA	Review of adequacy and frequency of training	Passed
TCPA	Review of adequacy and frequency of training	Passed

Vendor Review	Description	Comments
Ongoing Monitoring (reporting, audits, monitoring, reviews)	Reviewed audit frequency and findings	Passed
On Boarding (Questionnaire, Contract Review, Background checks, References)	Policy Exists Reviewed audits and frequency	Passed

Vendor Agreement	Reviewed agreements of TPPPs and ODFIs	Passed

Compliance Management Program	Description	Comments
Oversight	Reviewed organizational structure, authority, and personnel	Passed
Monitoring	Reviewed monitoring programs for adequacy and frequency	Passed
Training	Reviewed training programs	Passed
Complaint Management	Reviewed program, system to manage, and inability to edit	Passed
Written Policies and Procedures	Policy Exists Procedure(s) Exists	Passed

Public Internet Search	Description	Comments
Vendor Name/Keyword	Performed searches and examined all posts	Acceptable results
CFPB Complaint Database	Examined CFPB complaints, resolutions, and response timing	Passed

September 5, 2015

Author: sufyan

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3rd Party Vendor Management Services

Comprehensive Third Party Vendor Oversight

Consumers are at a real disadvantage because they do not get to choose the service providers they deal with the financial institution does, said CFPB Director Richard Cordray.

Consumers must not be hurt by unfair, deceptive, or abusive practices of service providers. Banks and nonbanks must manage these relationships carefully and can be held accountable if they break the law. CFPB

To satisfy Regulators, your third party oversight program must be comprehensive. What are the elements of a comprehensive third party oversight program?

Development of the Underpinnings

On-boarding

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Ongoing Audit Elements

Policy

Regulatory Compliance Policies & Procedures

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