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The Science Of Compliance...

Regulatory Compliance

The Interagency Guidelines Establishing Standards for Safeguarding Customer Information published February 1, 2001 and revised March 29, 2005, state that each financial institution has an obligation to ensure that each of its service providers has established a security program that is consistent with the Interagency Guidelines and guidelines set forth in the FACT Act of 2003. In addition, The Consumer Financial Protection Bureau (CFPB), FHFA, HUD and other agencies have established that lenders/brokers are accountable for vendor compliance with consumer protection laws and federal regulations related to mortgage lending. The policy sets forth minimum standards for lenders/brokers to manage the risks inherent in third-party relationships. The CFPB, empowered by Dodd-Frank as well as the Federal Trade Commission under the Gramm-Leach-Bliley Act (GLBA), calls for immediate compliance with these regulations through effective vendor management of third-party relationships. 

In a nutshell: lenders and AMC's now are accountable for vendor compliance. This type of regulatory environment is enough to give any compliance manager nightmares.  Given the nature of our client base and business model, compliance with the various layers of state and federal laws is mandatory. We adhere to a strict set of protocol regarding data security, transmission and storage. To that end, the AppraisalFlo Application meets or exceeds the regulatory requirements for:

 

  • Gramm-Leach-Bliley Act

  • Dodd-Frank Act

  • Consumer Financial Protection Bureau

  • Appraiser Independence Requirements

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The AppraisalFlo platform is designed specifically to mitigate the risk associated with appraisal management and allow to clients to deploy secure and compliant technology with confidence without sacrificing efficiency.  This is how we do it.

Automated Compliance

Infrastructure

Lenders have a choice:  they can "train" their problems away or they can "program"  them away.  It is an easy choice. Automated functions that assist regulatory compliance are:

 

  • Data Transmission and Security are ensured with extreme prejudice via our hardware infrastructure and extensive deployment of intrusion detection and remediation software

 

  • Confirmation of Receipt: Automated, interactive product delivery system confirms receipt of appraisal by the borrower

 

  • UDCP Direct Integration:  A direct connection to the UDCP ensures product delivery to the GSEs in a compliant format and immediate access to the SSR

 

  • HUD | ASC Eligibility:  Vendors are monitored daily for HUD and ASC eligibility

 

  • Communication Firewall: Appraiser independance is easily supported via our enhanced communication platform that inherently prevents unwanted communication between the lender | client and vendor

We have an entire page dedicated to infrastructure.   Some of the highlights are: 

 

 

  • Data Centers: Dual best-in-class SOC 1 (SSAE 16) examined Data Centers ensure the physical secuirty and infrastructure support necessary to maintain compliance

 

  • Redundancy: The AppraisalFlo network consists of 2 identical, redundant “Infrastructures" configured in a "east coast- west coast" configuration to ensure business continuity in the event that one facility is rendered inoperable by a disaster level event

 

  • Physical Security: The AppraisalFlo data centers use a comprehensive array of security equipment, techniques and procedures to prevent unauthorized access to our facilities

 

  • Virtual Security: Pursuant to the regulatory environment, all data handled by the Floserve Platform is considered to be confidential and is subjected the highest levels of security

 

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