The SPW got it's legs from the CFPB's 2012-03 Bulletin and filled a vacuum.
Not much has changed other than that others have gotten into the compliance fray for both lenders and NSA's.
Lender's Compliance Group now has a Vendor's Compliance Group -
http://vendorscompliancegroup.com/11.html
Another -
http://secureinsight.blog/2018/02/21/what-notaries-need-to-know-about-the-cfpb-the-occ-and-third-party-vendor-management-rules-affecting-residential-mortgage-closings/
So depending on who you're talking to...
http://www.consumerfinancemonitor.com/2016/10/26/cfpb-amends-service-provider-guidance/
"The CFPB has reissued its guidance on service providers which was formerly titled CFPB Bulletin 2012-03, and as published in the Federal Register on October 26, 2016, is now titled “Compliance Bulletin and Policy Guidance 2016-02.”
The reissued guidance includes an amendment that the CFPB described as “needed to clarify that supervised entities have flexibility [in their risk management program for service providers] and to allow appropriate risk management.” The amendment consists of the addition of the following language to the guidance:
The Bureau expects that the depth and formality of the entity’s risk management program for service providers may vary depending upon the service being performed-its size, scope, complexity, importance and potential for consumer harm – and the performance of the service provider in carrying out its activities in compliance with Federal consumer financial laws and regulations. While due diligence does not provide a shield against liability for actions by the service provider, it could help reduce the risk that the service provider will commit violations for which the supervised bank or nonbank may be liable, as discussed above." |
