“Banking regulators have increased their attention of third-party service providers and debt collectors as they seek to prevent consumers from unfair, deceptive and abusive conduct. Already, they have levied hefty fines on financial institutions for violations by such third parties.
Recent scrutiny of collections litigation, for instance, finds banks can outsource certain functions, but not compliance accountability. Both the bank and the vendors need to ensure payments are processed in a timely manner, bank and vendor systems are synchronized to reflect true account activity and collection attorneys are compliant with continuously changing state and federal laws.”
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