Contrary to popular opinion, no matter your size, you’re responsible for having a concrete, documented system to ensure you’re watching over your vendors and service providers. The law requires it. If you are a Larger Market Participant debt collector, debt buyer, or collection law firm, you fall under the direct supervision of the CFPB. As such, you must have a robust and meaningful service provider management program in place. The CFPB will include service provider management in its examination of your organization, and hold you accountable for its requirements. For those of you who are service providers, pay special attention to the fact the CFPB also has the power and authority to supervise you if you are a service provider of supervised organizations and Larger Market Participants.