Vendor Management Program
Outsourcing is a helpful, often times necessary expenditure of your time and resources.
More accurately, it can equate to a savings of your time and resources. Depending on the service provided, outsourcing some of your needs can also lead you to the procuring of services that you would not otherwise have available to your in-house staff.
We refer to all of these outsourced service providers as vendors.
It stands to reason that as you and your employees are bound by the standards of the Fair Debt Collections Practices Act and the Consumer Financial Protection Bureau that any company or service provider working for you and given access to your client’s data would be subject to those same regulations.
So, you must build and maintain a Vendor Management Program.
It should contain the following features:
– Your due diligence checklist for determining your vendors’ ability to comply with federal consumer financial laws
– Your policy to request and review the vendors’ policies, procedures, internal controls and training materials
– Copies of contracts with each Vendor, which should contain provisions for clear, enforceable expectations for compliance, including consequences for violations
– Your policy for on-going monitoring of the vendor for the purpose of determining compliance with federal consumer financial law
– Your policy for the timely addressing if problems identified through the monitoring process, including possible termination of the vendor relationship when necessary
A quality vendor management program can be cumbersome to develop and implement at first. However, once running smoothly, a single in-house employee can keep it operational with relative ease. After that, it becomes clear that the gain is worth the work.
An ounce of prevention is worth a pound of cure.
Drop by next week for Better Business Practices, Part IV on skip trace waterfall procedures.