One area that is too often neglected when it comes to the vendor due diligence process is the prospective partner’s document signing protocols.
There are a number of functions that require third party partners to produce signatures on behalf of their clients. When performing this type of work, accuracy and adherence to client requirements are essential. To deliver that, the firm must have a well-designed and compliant system.
The first element of such a system is a well-trained staff. Everyone associated with the process must have very deep training on our industry, its practices, and compliance requirements. Compliance requires that every employee has full knowledge, familiarity, and integrity on each and every document the firm signs on behalf of a client. This knowledge should be imparted through detailed and monitored training, but that’s just the beginning.
A well-trained staff will need the aid of efficient systems and technology in order to ensure that every document is signed correctly every time. Such a system of controls must include a signing authority database, frequent internal audits, and physical location controls that determine where employees are located throughout the facility.
In regards to training, notaries should be required to attend document review training and document reviewer specialists should likewise be required to attend notary training as well. This cross-training will ensure that all employees, regardless of position, understand what has to happen to ensure compliance.
Advanced database technology should be employed to hold detailed client records that will determine what documents company personnel can sign and under what circumstances. Power of attorney and corporate resolutions should also be held in this secure database.
Physical location controls should be employed to determine where employees work, as well as their proximity to each other and to notaries. This will allow the company to orchestrate the workflow and ensures that no document that must be notarized can leave the area without being thoroughly completed.
If it sounds like the vendor partner should build its company around signing controls instead of adding signing controls to an existing company, that’s correct. Any company who does not do this is not taking compliance seriously enough to mitigate the risks that face today’s financial servicing companies.
An easy way to tell how well the company is doing is to ask about their compliance record with the nation’s County Recorder’s Offices. If more than a fraction of one percent of their documents are being returned for compliance errors, one can bet that firm is making other errors that will expose anyone who hires them to significant risk.
Another excellent measure of the firm’s ability to meet the needs of its clients is to ask whether any of them are now adopting the partner’s document signing practices in their own companies. It happens.