Benefit — marketing-to-underwriting funnel record
What service-provider funnel evidence actually saves you
Circular 2023-03 says the bank owns the compliance stance of the AI marketing + AI underwriting service-provider stack. Independent-verifier evidence covering both ends creates the record CFPB looks for.
Where the funnel record shows up
- Vendor-stack CFPB probe. When CFPB tests service-provider UDAAP theory, the probe covers both the marketing vendor and the underwriting-AI vendor. Independent evidence on the seam changes the probe's opening frame.
- Vendor-contract remediation. Findings under Circular 2023-03 commonly require vendor-contract amendment. Getting ahead of the finding preserves negotiating position with the vendor.
- Vendor-diligence board deck. Board committees increasingly ask for AI-vendor-stack governance evidence. The Snapshot covers that ask for the credit-underwriting vendor.
Dollar frame
Vendor-stack consent-order scope: Circular 2023-03 findings commonly expand consent-order scope to name the vendor stack. Remediation cost then compounds with vendor-relationship rebuild cost. Typical mid-market range: $10M-$75M+.
Vendor-contract renegotiation under fire: vendor-contract amendment under CFPB consent-order pressure typically shifts 5-20% of contract value to vendor at bank's expense, with unfavorable indemnification terms.
Preventive stance value: $499 Snapshot creates the funnel-monitoring record proactively. The bank retains vendor-negotiation position rather than losing it to enforcement timing.
Who at your org cares
- Chief Marketing Officer — marketing vendor stack ownership
- Head of Consumer Credit — underwriting vendor stack ownership
- Chief Compliance Officer — vendor-diligence documentation
- General Counsel — vendor-contract stance
- Board Risk Committee — vendor-stack oversight
What "having it" looks like
Green: Snapshot on file covers both funnel ends. Vendor-diligence record is dated and independent. Vendor-contract position retained.
Red: no funnel-spanning record. CFPB finding names vendor stack. Vendor negotiation happens under consent-order timing pressure.
$499. 3 business days.
Independent record spanning the marketing-to-underwriting funnel — the vendor-stack diligence CFPB looks for.
Buy $499