Stick to Your Core!
Ask any athlete and they will tell you they perform well when they have a strong core. The same is true for business.
This recent settlement with US Bank highlights many lessons we can all learn regarding add-on products. When you go outside of your core business and participate in add-on sales to clients be careful of third-party vendor management issues.
As you can see, CFPB is taking 3rd party vendor management oversight very seriously and if they do not believe that you have strong controls in place then the fault falls to you as the lender.
Your core business will keep you strong when managed well, and keep the door closed to further scrutiny until we are all clear on what to do and when to do it!