Posted by Jose Ramon Maestre on 12/12/13 6:26am
Msg #495861

Need your input and help

Recently a member of our group, (ANSA) reached out and spoke with the chairperson in charge of "third party relationships" at the OCC. We are also doing the same with the CPFB.
Hs conversation was about BGC requirements. The gentlemen at the OCC requested we come up with some specific concerns and issues we could provide him, that he could then answer about BGC. This is a cut from that email report on the call,

"His bottom line is there are no minimum standards published by the government, it is up the the Financial Institutions to do their own due diligence on the people who are critical and based on the assessed risk they present to it. He went on to state that the Appraisers and Home Inspectors were voicing the same concerns. Their organizations have been contacting them as well on their requirement to comply with this guideline, so it is not just the notaries. He said if we can or will come up with some critical questions to have answered he gave me his personal email for work and said if I would send those questions to him he would direct them to the body he called Retail Lending Folks who would reply to our concerns and questions. There is so much turmoil out here concerning what the requirements may or may not be for us as notaries in meeting the requirements." So my request for help is simple, Please email me any specific questions you would like to be addressed by the OCC & CPFB. you can email me or PM here @ NR. or you can use our ANSA email @ [e-mail address]

Thanks for your input and help!
Jose R Maestre
President, American Notary Signing Agents, ANSA

Reply by MW/VA on 12/12/13 9:12am
Msg #495873

The main problem is the limit set on which bgc's will be

accepted. I, along with many others, have a bgc through NotaryRotary. IMO there is absolutely no reason this isn't acceptable. It's not like we're refusing to provide a bgc. The main issue is about submitting to the "industry standards" created by NNA. In my experience, whenever they are involved in our industry they create a lot of havoc that does more harm than good.

Reply by jba/fl on 12/12/13 9:24am
Msg #495874

I agree. They structure it so that there is something diff=

erent from anything else, then actively sell it as the "standard", as though there is such a 'standard'.

Reply by Jose Ramon Maestre on 12/12/13 9:26am
Msg #495875

Re: The main problem is the limit set on which bgc

I agree with you 100%. My BGC is also through NR. I have the certificates and the complete report. The NR BGC also allows for the vendor/ company you are using the ability to verify your BGC on the web. That is why we reached out to the OCC and are doing same with the CPFB.
We are trying to come up with answers and choices. The contact at the OCC has kindly offered to take questions and concerns and send them to the appropriate dept/individual who can provide an answer and some guidance. That is why i am asking for input and comments to be directed.
I would post the persons information but, that may just cause a flood or duplication. So we are compiling a list of concerns/questions to send.
Thanks!!

Reply by Notarysigner on 12/12/13 9:32am
Msg #495876

Re: The main problem is the limit set on which bgc

Jose, I have seen that OCC communication and it was very, very informative.

If it were me, I'd wait to see what the CPFB has to say and how they answer the SAME questions. Then I would compare them and if they are similar you might just begin to see the start of "an industry standard".
My .02

Reply by MW/VA on 12/12/13 9:41am
Msg #495879

Thanks for doing the work of compiling it. IMO it's almost

pointless for individual NSA's to flood these people with emails, etc. That's exactly why we needed an organization like ANSA to take this on. I would certainly like to see this "industry standard" claim by NNA challenged from a legal standpoint.

Reply by MW/VA on 12/12/13 9:43am
Msg #495880

Maybe someone knows an attorney who would take this on,

either "pro bono" or we could contribute for legal costs.

Reply by MW/VA on 12/12/13 9:43am
Msg #495881

I still think it has the implications of a class action suit n/m

Reply by C. Rivera Chicago Notary Services on 12/12/13 9:56am
Msg #495883

I agree with you MW in that I would love to see the NNA

challenged from a legal standpoint, not just on BGC, but on many of their other NSA industry standards.

I do believe, for now, if NSA's were to make sure they have their BGC up to date, regardless of where it was purcahsed from, and to also have a minimum of e&o, this would at the very least, let hiring parties know that from an individual standpoint, they are in compliance with the hiring parties standards, and not that necessarily of the NNA.

In order for hiring parties to see that the NNA is NOT the authority in our industry, its going to depend on the individual NSA to set up the challenge.

In other words, if a hiring party is asking you for a BGC from NNA, challenge them via email. Send them what you have, tell them to compare it with the one from the NNA in that what you have is sufficient. If they want to hire you, they will. If not, make a note of it in your files, and post here and on other NSA sites as this company BLA BLA is ONLY taking NNA BGC. I think someone should start a list, and post it online as to which companies are ONLY accepting NNA BGC.

I volunteer to handle this and if folks want to send me this information via email, please do so at [e-mail address].

I'll keep a posting on it online for members and non-members to see.

Its going to take the NSA to challenge each and every hiring party that insists using the NNA for BGC as well as for Certification. Many are also certified by the numbers site and NotRot.

I can combine this list with the latter information as well.

I can do all of this because work is slow for me right now, and its something I'm already working on anyway, so no major extra work on my part.

Industry standards created by the NNA, again, MUST BE CHALLENGED. It should first be challenged by the individual NSA.

Can't let others fight these battles, especially if nothing is being done about at the time you need it!

Reply by C. Rivera Chicago Notary Services on 12/12/13 9:58am
Msg #495885

of course any information sent to me, will be gathered in

confidence, and anonymity. I will never reveal my sources from individual NSA's unless given written consent to do so.

Reply by Notarysigner on 12/12/13 10:21am
Msg #495890

MW What you're suggesting is already being done

In one month we have almost 700 people who join up ready to bombard on command.

They are all unhappy, and want to do something about it. We are just gathering all the desired facts before pursuing!

Reply by MW/VA on 12/12/13 10:37am
Msg #495893

Thanks to everyone who is working on that effort. ;-) n/m

Reply by Notarysigner on 12/12/13 1:10pm
Msg #495913

Re: Thanks to everyone who is working on that effort. ;-)

You can email me anytime if you want to know what's going on. [e-mail address]

Reply by CarolF/NC on 12/12/13 4:30pm
Msg #495926

Everyone but me. I'm blocked. n/m

Reply by Notarysigner on 12/13/13 7:54am
Msg #495988

You're a member and post on the site... n/m

Reply by JJNotary/CA on 12/12/13 6:12pm
Msg #495936

That is promising. Asking for input, and it not just being a small group of frustrated notaries. Those are both good signs.

And I think it shows that what all this boils down to is in the absence of another solution, TC are going with the only one presented. Perhaps, since they really are walking on thin ice right now - they are starting at an extreme in how they handle 3rd parties, and then when the various government agencies tell them it's too much, later the TC's can say 'you told us this was fine' and help cover themselves, a bit as well.

Alright - I digress! I'll finish reading the comments before I add my questions, in case they were already brought up.