I have to agree with what some of the posters have already said. No matter what comments or questions you ultimately present to the panel, keep the focus on how the consumer is affected or harmed, which is the CONSUMER FINANCIAL PROTECTION BUREAU’s sole purpose in being. If you look back at some of the suits that the CFPB has brought against companies/entities, the majority of claims center on how the customer/consumer was financially harmed or potentially at risk due to or as a result of ______(fill in the blank).
What, if any, is the actual risk to the personal information of the consumer because TC/SS don’t pay their notaries? Is that a federal, national level jurisdictional issue? Or is that a local/state level jurisdictional issue? How does that affect the big banks/lenders/companies, or does it at all? Background checks for employees of TC/SS have been mentioned. For the most part, TC/SS without BGCs for all employees operate without ever running afoul of the law. Also keep in mind that that piece of paper called a BGC is only good for a set point in time; five minutes after the information has been pulled the individual could be found guilty of a background-changing event. This is one of the arguments for annual checks.
Also keep in mind that notaries may, as far as the CFPB group is concerned, not be a separate group with needs, but be part of the group of third party-vendors of the larger banks and lenders, possibly direct behind TC/SS. Whether we as a group get paid, or what we get paid, isn’t the concern of CFPB. Doesn’t affect the consumer. In their mind, they are probably thinking we should take it up with “the boss”. They are focusing on the bigger fish of lenders/companies that they can make an example out of and control. Plus, those groups of bigger lenders/companies already have standards and procedures set out for them by the CFPB, and it may come down to CFPB saying we have to play by those rules, and not make up new rules just for us. |
