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to handle compliance matters is an account
representative handling the vast majority of
inquiries – limiting an FI's contact with other
servicing staff prior to contract signing. Others
include a servicer's lack of detailed information,
coupled with responses such as, "Mr. Smith has
been handling that for years," "we're a national
service provider," or "our audit department
handles that."
OVERSIGHT AND TRAINING
Assessing a provider's management oversight
and training is the most comprehensive of these
five requirements. It is necessary both prior to
contracting with the provider and over the life of
the relationship. Even after a full, pre-contract
evaluation, the FI will not have seen how the
provider's eloquently stated training program and
controls are applied to its portfolio of assets. An
FI's review should include a review of third-party
policies, procedures, training materials and
records, internal controls, and other tools used
for management oversight.
While training is complex in terms of topics,
its assessment is not complicated. A strong
training program at a service provider would
include classification of employees into job roles,
documented mandatory compliance (and other)
1. COMPLIANCE DUE DILIGENCE
2. ASSESSMENT OF SERVICE PROVIDER
OVERSIGHT AND TRAINING
3. CONTRACT TERMS
4. CONTROLS & MONITORING
5. PROMPT ACTION TO ADDRESS ISSUES
COVER
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INDUSTRY
INSIGHT
INDUSTRY
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