Each lender and/or title co is able to make their own decisions about that. The law and the CFPB bulletins only outline that the lender will be responsible to ensure the security of borrowers/consumers private information, and that includes for all their contractors and subcontractors. It's up to them how they go about it, but they all need to be able to document the steps they've taken to accomplish that. Presumably, requiring BGCs for those who have access to that info at any stage is ONE of the methods that most have chosen to meet that obligation.
XYZ has managed to convince many that their services (including BGCs and certifications) are the best way for those companies to handle those issues relative to notaries. The SPW is another approach they're using. For more info on the SPW - which we'll likely be hearing more and more about as we get closer to the Oct deadline - there is abundant info available via the search button. |
