finxera

Finxera Inc, // Crossroads Financial Technologies

Subscriber Add On Program Underwriting Procedures and Requirements

Author: Joseph Duarte

Revision: 1.0
Date: May 31, 2017

Overview:

This document will provide the procedures and requirements for reviewing, underwriting and approving;
services, programs; and vendors (Add On Programs) offered by CFT Subscribers to customers enrolled
in a debt settlement program by CFT Subscribers.

CFT has a responsibility to ensure Add on Programs are compliant with TSR guidelines and do not
adversely impact the customers ability to successfully complete the enrolled debt settlement program.
CFT has a further responsibility to ensure vendors offering the Add on Program compliance review
including OFAC screening prior to facilitate transfer of fees earned by the vendor.

Add on Programs include but are not limited to:

Credit Monitoring Services
Legal Support Programs
Lending and Debt Consolidation Programs

Add on Programs and Vendors must meet at a minimum the following requirements:
1. The Add on Program has to be offered to the customer on an Opt In basis and the
customer can Opt Out at any time
2. The customer must sign a CFT provided Draft Authorization with the amount date of funds
to be transferred from the customers SVA to the Vendors fee account
3. The Subscriber must have no ownership of the Vendor offering the Add on Program
4. The Vendor offering the Add on Program must submit a completed Vendor Intake
Form along with supporting documents that at a minimum include articles of
incorporation and copies of marketing material (if any) related to the Add on Program
5. Execute the Finxera Processing Agreement or other agreement acceptable to the
Finxera.
6. Provide contacts and procedures for handling customer complaints and refunds.

Approval Process:

Prior to approval of the Vendor and Add on Program Finxera will complete an internal review and
underwriting process for the Vendor and Add on Program. A check list with all supporting documents
will be submitted to Compliance for review and final approval.

Underwriting of the Vendor and Add on Program will consist of the following:

55 South Market Street, Suite 1220, San Jose, CA 95113 Tel: 650-294-4450
www.bancbox.com
www.finxera.com
finxera

Completion of OFAC screening of the vendor and principals based on the information supplied in
the Vendor Intake Form
Completion of a background check and review of principals of the vendor
Evaluation of any marketing material supplied by the Vendor to ensure the material does not
violate UDAP guidelines
Evaluation of the Add on Programs fees as it relates to the total cost to the customer for
completion of their Debt Settlement Program. The Add on Program fees will be evaluated using
the Program Fee Analysis spreadsheet.
o Fees as a Percentage of Savings should not exceed 100%

Add On Program Setup and Operation:

Once the Vendor and Add on Program have been approved by Compliance the Vendor, Add on Program
and associated fees will be added to CFT Pay UI and assigned to the Subscriber.

Add on Program Process

The Subscriber will be required to schedule all fee dates and amounts in their CRM or the
CFT UI.
Prior to the processing any fees the Subscriber must submit a Draft Authorization listing
the dates and amounts for Add on Program fees. Submission of the Draft Auth may be
completed through the CRM or emailed to an assigned CFT email address
Compliance Operations will confirm the Draft Authorization matches the dates and
amount of the fees scheduled in the CFT UI.
Exception reporting will be used to the ensure the Add on Program fees charged do not
exceed the fees setup in the CFT Pay UI
Completed fees will be transferred to the Vendors assigned account
o If required the CFO and/or COO will set and require reserve amounts in the
Vendor fee account.
The Account Management team will monitor any complaints related to the Add on
Program; any complaints will be addressed with the Subscriber for review and resolution.
Finxera maintains the ability the halt the processing of Add on Program fees in the event
of customer complaints or compliance concerns.
Compliance will conduct regular reviews of the Add on Program and Vendor to ensure
compliance with Finxera policies is maintained

Supporting Documents:

Documents necessary for the approval and setup of the Vendor and Add on Program that will be included
in the Add on Program and Vendor Checklist include:

Vendor Check List listing of all documents and confirmation of requirements

Vendor Intake Form - information related to the vendor and principals
Draft Authorization Form Add on Program specific draft authorization form for the program
Executed Finxera Processing Agreement or other agreement
Add on Program Marketing used in marketing the program to subscriber customers
Program Fee Analysis

55 South Market Street, Suite 1220, San Jose, CA 95113 Tel: 650-294-4450
www.bancbox.com
www.finxera.com
finxera

OFAC and background screening results

55 South Market Street, Suite 1220, San Jose, CA 95113 Tel: 650-294-4450
www.bancbox.com
www.finxera.com