Clark Hill’s Financial Services and Regulatory Compliance Group has authored a whitepaper for debt settlement companies considering engaging a third-party payment processor for managing accounts and handling financial transactions. This whitepaper outlines and provides insight into the requirements governing oversight over third party payment processors; explores the various laws and regulations that are integral for a DSC when developing a robust and well-executed third party risk management program with its payment processing partner; provides an overview of federal and state enforcement actions when those laws and regulations are not followed by either a DSC or a payment processor; and finally, outlines key contractual provisions taken directly from the Interagency Guidance that should be considered by a DSC when entering into a business relationship with a payment processor.
Please see full publication below for more information.