Background Buzz Insider
June 16, 2015
In the May
edition of The Background Buzz, I ran
an article. 'NAPBS Accreditation Update.' As a result I was contacted
by Derek Hinton, President, CrimApollo, and CRAzoom, a company
that has helped many CRAs become accredited. He kindly provided
the following clarification of the article which he originally
my apology for any inconvenience or confusion that the article
may have caused.
I always enjoy your informative newsletter, The Background Buzz.
In the last
issue you featured an article titled "NAPBS Accreditation: The
Grandfathering Issue." Well, the more things change, the more
they stay the same-but that could change. And in this case things
have changed since that article originally appeared.
been some new guidance since that article. It says:
BSCC specifically published (in response to a letter inquiry
made) on or around March of 2013 a document titled “Audit
Preparation,” which included tips (and can be found
on the napbs.com/accreditation web pages) and the following
specific recommendation with respect to Section 2.7: If
a CRA is in the process of securing amendments with this
information, do not schedule an audit until up to date agreements
from all clients have been secured.
position of the BSCC on the issue remains the same.
short, organizations seeking accreditation must secure current
contracts with active clients and vendors which are in compliance
with all audit criteria in order to effectively satisfy
the accreditation standards.” http://portal.napbs.com/files/resource_library/Accreditation/Agreement_from_Clients.pdf
So what is
the specific recommendation with respect to Section 2.7?
with audit criteria states in part:
Verification for Onsite Audit
requested agreements predate CRA's application date for Accreditation,
auditor will only look to identify language regarding compliance
So, if a
client agreement is lacking any FCRA certifications, those agreements
(even those that predate application) must contain all required
FCRA compliance language. But let's face it, obtaining certification
from clients is FCRA 101 and if a CRA is not doing so, accreditation
or not, it needs to be done.
are ways to mitigate the task and in fact, use the task as a marketing
tool with clients. Compliance is becoming the name of the game.
hope this helps your readers.