Inundate, Mandate or… Not-So-Great
The Consumer Financial Protection Bureau (CFPB) is a government agency assembled to protect the general consumer from financial institutions against unfair, deceptive or abusive acts or practices (UDAAP). Dating back to the start of the CFPB in 2011… its regulatory oversight today has become more intrusive and intervening than any government agency throughout U.S. history. That said, it’s oversight is anything but optional. Those lenders that truly understand its impact are awaking to the reality... the CFPB is here to stay!
At ENDTRUST, we've embraced the fundamental intent of the CFPB as it pertains to the automobile asset recovery, remarketing and lease-end management servicing industries. We've partnered with affiliate technology service-providers who are out front leading the industry with compliance regulation. It’s our firm belief that by having policies and procedures in place that align with CFPB compliance requirements, we’re optimizing our efforts toward “zero-tolerance” of prevention against any such referenced unfair acts or practices.
Vendor Vetting – ENDTRUST’s Vendor Management Quality & Compliance Assurance Team (QCAT) ensures its industry “Compliance Standard of Excellence” (CSE) is not only met but then maintained on an on-going basis with each and every recovery agency within its “Super Agent Network” (SAN). Financial stability, background checks, random drug testing, training certification, compliance & operations manual utilization and continuing education are all part of the vendor vetting process managed by ENDTRUST’s QCAT.
Vendor Lot Inspections – ENDTRUST, via its affiliate relationship with Vendor Transparency Solutions (VTS), oversees annual vendor lot inspections that include on-site visual audit-review to ensure: secure office facilities, data security, qualified secured fencing of property, compliant procedures, designated storage areas for personal property inventory and keys, visible utilization of Policies & Procedures Manual, presentable vendor employee dress attire and adequate security to accommodate customer redemptions in a safe and secure lot environment.
Super Agent Network (SAN) – ENDTRUST’s Vendor Management QCAT is responsible to ensure its Industry “Compliance Standard of Excellence” (CSE) for its Super Agent Network is not only met but then managed and maintained to meet and/or exceed these minimum requirements:
In joint-effort with it's affiliate technology & compliance servicing partners, ENDTRUST provides:
> Verification of Criminal Background Screening not only of
principals/owners but also individual employees of all
affiliate business entities
> Verification of proper licensing
> Verification of insurance and bond coverages
> Validation and tracking of all industry certifications
> Tracking of on-going employee education
certifications and training
> Tracking of Consumer Complaints
> Company bankruptcies and lawsuits
> On-Site office/lot inspections together with an 80 point compliance inspection
> Corporate Financial Statements
> State Certificate of Good Standing
> State Formation Certificates
> Tracking of Minority Certifications
> Maintaining service provider’s Policies and Procedure, Employee Handbook, Complaint Handling and Disaster
> Disaster Recovery manuals
>> On-going employee background checks
>> Random Drug Testing
>> Annual lot inspections
>> Adequate insurance coverage provisions
>> Training & Continuous Education
>> Complaint & Incident tracking
>>> Consumer Dispute Form