Compliance & Risk
The FFIEC (Federal Financial Institutions Examination Council) agencies have stated that appraiser selection is the single most important step of the appraisal process. Clearbox was founded to fully align with this fundamental core belief that the “people part” of the process is the most critical step. Clearbox maintains a database of every licensed appraiser in the US. We are now expanding into other sectors of the housing finance system.
We have created the portal for your vendors to complete their own profile with all of their credentials necessary to properly vet them. In the case of appraisers, we verify their licenses and have collected consent orders for any disciplinary actions (X-Files™). The vendors order their own background check relieving you of any compliance risk with FCRA. Clearbox is the only source offering a holistic solution for vendor management.
The current guidance on vendor management suggest that lenders, as well as their agents, are responsible to 1) initially vet their panel and 2) constantly monitor. Our tools automatically notify you if a vendor has an incident affecting their background check or if a disciplinary action has been issued.
Dodd Frank mandates that a complaint must be filed for any substantive violation of USPAP. We have created an automated tool, CBOX™, to assist with this process. We have standardized a compliant process and provide electronic tracking and storage of each complaint.
Customary & Reasonable Fees
Dodd Frank also mandates the payment of Customary & Reasonable Fees by both lenders and AMCs. The law suggests that these fees may be determined by 1) academic studies, 2) independent fee surveys and 3) government fee schedules. We have you covered with all of the angles. Our fee survey is the most comprehensive available.
If you are an AMC keeping up with State AMC Laws is a full time endeavor. If you are a lender you are required to ensure that any third party you may select is compliant. We have created the tools and manage a database of all AMC registrations, laws and legal commentary.