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Desired Capabilities

  • Program Build Out
  • Gap Closure
  • Compliance Management

The Situation

An employment background check and screening company needed help. The company had recently received a consent order from the Consumer Financial Protection Bureau (CFPB) requiring them to put together a compliance plan to quickly rectify its failure to meet specific regulatory requirements. The company did not yet have much experience with the CFPB and the regulatory feedback was complex to decipher. Knowing they needed to leverage a third party with expertise in this area, the company turned to Spinnaker.

The Challenge

Quickly and effectively make the company compliant with a federal regulatory deadline and meet CFPB expectations.

Meaningful Outcomes

  • Built a compliance plan and program that aligned the company with federal regulations.
  • Coached key staff on best practices for working with the CFPB and other regulators on future engagements.
  • Developed a new process to reduce future errors, resulting in a more than 25% decrease in customer complaints and more cost-effective processes.

Spinnaker’s insight and perspective set us up well to address regulator concerns and get back to a place of good standing. Executive Vice President, national employment background check company

Our Approach

We began by conducting our own independent assessment of the company’s key processes to better understand the root cause of the previously identified gaps.

Then, based on our findings, we outlined the essential issues and detailed the steps the company would need to take to become compliant. We then worked with
the company to get the compliance plan submitted, coaching the staff along the way on what to expect from conversations with the CFPB and how to work with regulators on future engagements.

In addition to aiding with communication between the CFPB and the company, we also built out a step-by-step compliance program for the company, detailing what it needed to do — and when — in order to become compliant.

Throughout the year, we checked in regularly to ensure all the necessary steps were being taken and the company was on track with its commitments to the CFPB.