We have produced and made available a Compliance Assessment to provide users with a profile opinion of their regulatory compliance activities. The assessment is based on both original material by Compliance Umbrella and on the CFPB Examination Manual, a U.S. Government Publication available for use by the general public. It specifically uses the portion of the CFPB Exam Manual titled Consumer Risk Assessment, located at www.cfpb.gov, page 855.
This assessment is presented at no cost to the taker. You may download the document and answer the questions as indicated. You'll tabulate your own score and see our opinion on your present level of compliance.
The assessment should be taken by the business owner or an upper management person in order to have any value to the business; the intent is that the answers come from a decision maker/leader in the company who would know the answer to each question. Answer quickly and honestly for the most authentic result.
STATEMENT OF INDEMNIFICATION:
We do not hold ourselves out as experts nor guarantee or intend any level of accuracy in assessment results. Our opinion of the results is based on Best Practices in the industry and on the intentions of the CFPB in the content of their Risk Assessment.
Attorneys and Collectors active in the following areas need to consider how and why CFPB is a concern:
It only takes one activity to make a law firm (in the words of the CFPB) a "supervised entity." And all collectors and Collection Agencies are responsible for CFPB compliance. A common question from attorneys is, "We're not a bank, we don't lend money, so no compliance responsibilities under ECOA, EFTA, etc." However, if any law firm clients are in financial services, they have likely sent your firm a VRA (Vendor Risk Assessment) because they have been informed by the CFPB that they need to monitor and ensure that service providers (such as law firms or collection agencies) are CFPB compliant, have a functioning CMS system and can verify that to the bank client. If their law firm or collection agency is NOT CFPB compliant, well, there are problems with that engagement. A Consent Order this year cost Citibank $735 million in restitution and penalties for failing, among other things, to manage their vendor/service provider risks.
COLLECTIONS (LAW FIRMS): The primary compliance responsibility for attorneys is in the area of collections. This is because Courts routinely have found attorneys who act for a client to recover a debt in default are legally collectors and are responsible for the requirements of the Fair Debt Collection Practices Act. Assisting law firms with this, Compliance Umbrella licenses a complete Compliance Management System, populated with the FDCPA procedure, lesson and quiz.
OTHER COMPLIANCE AREAS: Hiring practices and normal operations bring into play numerous other procedures - contained in our CMS, including Fair Credit Reporting Act, American With Disabilities Act, UDAAP, Info Security Program, HIPAA (re PHI) and data breach notifications. We also provide Procedures on Payday Loans, Student Loans, Servicemember's Relief Act, and a summary analysis of all 57 CFPB Consent Orders.
STATE COLLECTION AREAS: We present a directory of state laws, a summary of all state versions of FDCPA, state information/citations to Data Breach Notification laws, and others.
VENDOR RISK PROGRAM: A complete program covering risk assessments, monitoring vendors, contract provisions, verifying to clients, an ATTESTATION document - is included for all law firms and collection agencies. The program is 3-dimensional, enabling you to look back and provide what's needed for your clients - and - to look forward to manage and ensure compliance from your vendors.
PRICING: A low-cost single license covers all employees. Starting in 2016 our license fee will be tiered to the size of the user company. Our pricing is $199/month. If you subscribe for 12 months, this is discounted by $477 and the annual subscription is $1910.40. Click Signup (upper right corner) to subscribe.