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ARTICLE · 25 MAY 2012

Consumer Financial Protection Bureau Issues Outsourcing Guidance

Dechert
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On April 13, 2012, the newly minted Consumer Financial Protection Bureau (CFPB) issues CFPB Bulletin 2012-03 on the topic of Service Providers that, while using different words does not vary substantially from the supplier guidance issued on this topic from other financial service regulators, thankfully.

United StatesEmployment and HR
Vivian Maese
Vivian Maese

On April 13, 2012, the newly minted Consumer Financial Protection Bureau (CFPB) issues CFPB Bulletin 2012-03 on the topic of Service Providers that, while using different words does not vary substantially from the supplier guidance issued on this topic from other financial service regulators, thankfully.

While relationships with service providers are viewed as potentially useful, the bank remains responsible for complying with Federal Consumer law to avoid consumer harm.

In addition to regular bank examinations, the CFPB will have supervisory and enforcement authority over the Service Providers.

An effective process for risk management and governance is expected.

To ensure that the contracts with Service Providers do not pose unwarranted risks to consumers, the following steps are recommended:

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