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How EZ Inspections & Preservation Ensures Regulatory Compliance Tim Doehner |
| 3/15/2018 |
| EZ Inspections is the leading cloud and mobile-based software platform for property inspections and property preservation. EZ's infrastructure is 'cloud-based', giving our customers unlimited access to computing power, network bandwidth, and storage capacity, as well as reliable data redundancy, file back up, and enhanced security. |
| EZ's mobile apps on iPhone / iPad, Android and Windows let inspectors and preservation contractors easily collect data, photos and signatures, and upload to the cloud in real-time. Our web platform lets office managers manage order creation, dispatch, QC and submission anywhere, anytime and on any device. |
| A brief history of background checks and compliance |
| The idea of and requirement for background checks in the mortgage field service industry has been around for several years. Servicers' contracts with their National vendors and the Nationals' contracts with the Regional vendors required securing background checks for all employees and independent contractors, including the contractors in the field who were actually accessing the property. The system broke down much of the time and compliance and/or enforcement failed at many stages of the process. |
| The financial and housing crisis of 2008 brought several permanent and long reaching changes to the banks, mortgage companies and the field service industry. The Office of the Comptroller of the Currency (OCC), part of the Treasury Department, which oversees bank operations, began to implement several new regulations in an effort to: |
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• Better manage risk in the broad housing industry • Increase accountability for all third party vendors with whom the banking industry dealt • Manage and oversee the controls being put into place by the financial institutions |
| As part of the field service industry's approach for more and better controls and credentialing of its vendors, a standard background check process was developed. |
| The industry standard background check |
| Several default servicing industry stakeholders recognized the need for the standardization of the background check process as being the first step in complying with the new OCC regulations. While accomplishing this objective would be a challenge, the benefits derived from standardization were seen to be: |
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• Uniformity in the methodology used for the background check criteria • Creation of a single repository for the background checks • Provides tracking of the vendor network including from work order issuance to completion • Increased insurance of vendor compliance • Added credibility and professionalism within the field service industry • A single background check to be used across all of a vendors' clients |
| The driving force behind the standard background check process was the servicers/lenders themselves. They viewed the process as a major step in satisfying the OCC regulations and in their own efforts to manage exposure to additional regulation, risk and consumer complaints. |
| A working group was formed to create the content, criteria and workflow of the process. The group was made up of: |
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• A major bank servicer • National field service providers • A background check company • The National Association of Mortgage Field Services (NAMFS) • Aspen Grove Solutions (AGS) |
| After several months of fact-gathering and deliberations between all the various factions listed above, the result is a system known as Aspen iRecord which resides within Aspen Grove Solutions. AGS is an enterprise technology solution provider in the property and real estate sector. |
| What is Aspen iRecord and how does it work? |
| Aspen iRecord® is an independent technology platform incorporating vendor management capabilities and the industry standard background check to enhance operational efficiencies, consumer safety, and consumer compliant management capabilities for all stakeholders in a simple, easy-to-use online portal. It supports organizations who wish to comply with the guidance of regulatory bodies, such as the CFPB and OCC, regarding mitigating consumer risk when using third-party vendors. It simplifies the background check process, while ensuring appropriate controls and procedures are in place for all parties through line-of-sight capability, from point of work order assignment, to point of service delivery. |
| There are forty-two (42) criminal charge categories which are checked. AGS developed a system that would collect and verify the individual's background information including: |
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• Social security number verification • Felonies, misdemeanors and active deferrals – based on 7 year residence history • Sex offender – State – based on 7 year residence history • National criminal record • Federal criminal record – based on 7 year residence history • Global sanction – FBI Most wanted, Office of Foreign Asset Control, etc. |
| Based upon the findings from the background check, an industry decision matrix will assign an ICO number, not just a pass or fail ranking. A status of ICO1, ICO2, ICO3 and ICO4 will be determined for each individual who has gone through the process and a unique id or ABC# will be assigned to the individual. Additionally, a standardized appeal process has been established to address any disputes which may arise from a status assigned other than ICO1 which is the highest level of compliance. |
| A major component of the process and an important objective that the stakeholders were tasked with achieving is the check-in procedure at the properties where the work is being performed. The individual actually accessing the property will be identified by using his/her ABC# while the system confirms the location of the property by using GEO coding and confirms work completion by using date and time stamping on the work order photos. |
| What was EZ Inspections & Preservation's role in the check-in process? |
| Being a leader in providing third party inspection and property preservation software to the field service industry, EZ worked closely with Aspen Grove Solutions and the National field service companies to develop a seamless integration of on-site check-in, GPS location tracking and the additional ten questions/answers required at the time of check-in. |
| For any work order that requires check-in, EZ has made the process seamless to the field representative. Once the ABC# is entered into the EZ field rep profile, all the work is done by EZmobile and the EZ cloud system in the background. The process is transparent to both administrator and the field rep, who only has to complete the additional required questions. The check-in and additional information will be submitted to the client as well as Aspen Grove Solutions by EZ's data entry function. |
| What does the EZ user need to do to ensure compliance? |
| First of all, as administrator, please be sure to enter each individual Aspen iRecord or ABC# into the field representative's profile in EZ's system. Keep in mind that the ABC# and the representative's Last Name must match the information that is stored in AGS' database in order to be accepted (this can be verified by the system admin). Update EZ Inspections & Preservation for Aspen iRecord by following these instructions: |
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• Login as an Admin user • Go to Contacts/Users • Click on the field rep's last name • Scroll down to the field marked "Aspen compliance profile" • Enter the ABC# for the field rep (make sure the Last Name matches the name in AGS' database) • Click on Update at the bottom of the screen |
| The check-in process will be done automatically and the ABC# will auto-fill as the field rep completes the work order using one of the EZ apps. Needless to say, accuracy cannot be stressed enough. In order to be in compliance with the OCC, Servicer and National field service company requirements, administrators and users must be accurate, thorough and timely in updating information to the EZ profile screen. |
| The enhanced background check and the on-site check-in process are seen as major steps forward in financial institutions compliance with federal regulation. These new measures have been viewed as challenges by the field service industry and the many customers that EZ serves but through cooperation with all of the industry stakeholders – servicers, National field service companies, background check companies, the industry trade association and third party software providers, EZ Inspections & Preservation has made compliance easy for its users. |