Author: sufyan

VPCS Awards QuickSecureCash 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 QuickSecureCash 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 QuickSecureCash to be operating a compliant organization as of the date of the review and passed our background review.

Please consider QuickSecureCash 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 QuickSecureCash 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 TheCashProvider 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 TheCashProvider 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 TheCashProvider to be operating a compliant organization as of the date of the review and passed our background review.

Please consider TheCashProvider 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 TheCashProvider 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 Speedy Online Cash 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 Speedy Online Cash 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 Speedy Online Cash to be operating a compliant organization as of the date of the review and passed our background review.

Please consider Speedy Online Cash 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 Speedy Online Cash 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 ATM Cash Loan 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 ATM Cash Loan 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 ATM Cash Loan to be operating a compliant organization as of the date of the review and passed our background review.

Please consider ATM Cash Loan 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 ATM Cash Loan 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 Top Tier Cash Loans 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 Top Tier Cash Loans 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 Top Tier Cash Loans to be operating a compliant organization as of the date of the review and passed our background review.

Please consider Top Tier Cash 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 Top Tier Cash 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 5, 2015

VPCS Awards Money Mutual Installment Loans 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 Money Mutual Installment Loans 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 Money Mutual Installment Loans to be operating a compliant organization as of the date of the review and passed our background review.

Please consider Money Mutual Installment 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 Money Mutual Installment 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 3, 2015

VPCS Awards MoneyMutual 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 MoneyMutual 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 MoneyMutual to be operating a compliant organization as of the date of the review and passed our background review.

Please consider MoneyMutual for any future lead gen services.

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 3, 2015

VPCS Awards Halsted Financial Services Call Center 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 or debt buyer a lender can trust when looking to outsource elements of their business or sell charged off accounts.

VP Compliance Services is pleased to announce Halsted Financial 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 Halsted to be operating a compliant organization as of the date of the review and passed our background review.

Halsted Financial Services provides comprehensive call center services from three operating centers. Their facilities in Chicago, Honduras and The Philippines allow their customers to match skill sets to the best labor market and cost, provide for 24/7 coverage and insure capacity availability. They provide call center services including lead generation, sales verification and conversion, ongoing customer service and support, and delinquency management. For more information please contact Rick Arko @ 815-479-1072 or rick.arko@halstedfinancial.com.

Please consider Halsted for any future 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 Halsted passed are listed below:

VPCS Call Center 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
ACA Accreditation	Detailed review of debt buyer’s policies and servicing practices	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
DNC Registry and unsubscribe maintenance	Based on marketing channels	Current and complete

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

Policy and Procedure Review	Description	Comments
OFAC	Policy Exists Procedure(s) Exists	Passed
Payment Processing	Policy Exists Procedure(s) Exists	Passed
BSA / AML	Policy Exists Procedure(s) Exists	Passed
EFTA / REG E	Policy Exists Procedure(s) Exists	Passed
FCRA / FACTA	Policy Exists Procedure(s) Exists	Passed
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
FDCPA	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

Payment Processing	Description	Comments
Vendor Agreement	Reviewed agreements of TPPPs and ODFIs	Passed
NACHA Requirements	Review policy vs NACHA Best Practices	Passed
Statement Review	Reviewed statements to ensure performance within required threshhold	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 2, 2015

Collections

VP Compliance Services’ Compliance Certified Vender program is an extensive review and audit of a Call Center’s policies, procedures, training, background and more. A Compliance Certified Collections Call Center is a Collector a lender can trust when looking to consummate a new vendor relationship.

VPCS will display all Certified Collections Call Center’s audit and review results. Interested parties may reach the Collections Call Center’s certification page by clicking the VPCS Certified Vendor logo on the vendor’s website.

VPCS’ Vendor Certification program is not recommended to replace a lender’s own vendor review program. It may be used to help select a new Collections Call Center lender will select for consideration.

For more information on VPCS’ Vendor Certification program please contact William “Rick” Wittwer at wrw@vpcs.biz.

Collections Certification

Certifications & Accreditations	Description
Online Lenders (OLA) Accreditation	Certification
Debt Buyers Association	Certification
American Collectors Association	Accredidation
ISO	Certification
CLLA	Certification
SAS70	Certification

Company Background Check	Comments
Liens, Actions, Fines, Investigations	Lexus Nexus Company Background Check
CFPB, FTC, & State AGs	Regulator Check

Licensing, Registrations, Bonds, and Insurance	Comments
State Licenses and Bonds	Review
Errors & Ommissions Insurance	Coverage Levels

Contract Review	Comments
Client Placement Agreement	Review of key elements of the agreements

Polices and Procedures	Comments
Fair Lending	Review of Policy (does one exist and is it complete?)
Identity Authentication	Review of Policy (does one exist and is it complete?)
GLBA	Review of Policy (does one exist and is it complete?)
Privacy	Review of Policy (does one exist and is it complete?)
Record Retention	Review of Policy (does one exist and is it complete?)
SCRA / MLA	Review of Policy (does one exist and is it complete?)
UDAAP	Review of Policy (does one exist and is it complete?)
TILA	Review of Policy (does one exist and is it complete?)
Vendor Management	Review of Policy (does one exist and is it complete?)
TCPA	Review of Policy (does one exist and is it complete?)
Information Security	Review of Policy (does one exist and is it complete?)

Information Security (GLBA)	Comments
Written Security Program	Review of Policy (does one exist and is it complete?)
Information Encryption used when transferring data	Review of Policy (does one exist and is it complete?)
Network Monitoring	Is 3rd party vendor performing?
Firewalls installed	Reviewed firewall technology and vendor
Default passwords and Security Parameters updated	Review of Policy (does one exist and is it complete?)
Protection against system attacks	Technology exists and is utilized
Restricted access to Sensitive Information	Review of Policy (does one exist and is it complete?)
Secure development of system and applications	Review of Policy (does one exist and is it complete?)
Physical Security	Review of Policy (does one exist and is it complete?)
Clean Desk Policy	Review of Policy (does one exist and is it complete?)
Facility Access Monitoring	Review of Policy (does one exist and is it complete?)

Audits	Comments
3rd Party	Review of any 3rd party audits performed
Client Initiated	Review of any 3rd party audits performed

Training (Employee)	Comments
TCPA	Review of adequacy and frequency of training
UDAAP	Review of adequacy and frequency of training
FDCPA	Review of adequacy and frequency of training

New Client On-Boarding	Comments
On Boarding	Review of Prospective Client Questionnaire, Contract Review, Background checks, & References
Underwriting	Review of Quantitative Decision Criteria Utilized

Compliance Management Program	Comments
Oversight	Reviewed organizational structure, authority, and personnel
Monitoring	Reviewed monitoring programs for adequacy and frequency
Training	Reviewed training programs

Complaint Management Program	Comments
Written Policies and Procedures	Review of Policy (does one exist and is it complete?)
Public Internet Search	Performed to identify additional areas of concern
CFPB Complaint Database	Debt Buyer

January 9, 2015

Compliance Certified Vendor Program

VP Compliance Services Vendor Certification program is a review and audit of the Client’s vendors whether they are debt buyers, lead generators, payment processors, call centers, or collection agencies. A VPCS Compliance Certified Vendor is a vendor you can trust when looking to outsource elements of their business:

Debt Buyer

Lead Generation

Call Center (sales and customer service)

Collections

Payment Processors

December 4, 2014