That's a good point. My bank and the bank in question are very small community banks that don't normally have products like this. My bank has secondary mortgages but that's about it. We control the CIP gathering process, not the third party. We manually run 314a on these as well. In the case of the other Bank and Upstart, this is the first product of this kind to be introduced and unfortunately there was no acting BSA Officer there at the time of product implementation (go figure). So in all honestly, we are trying to figure out what to do period.
This is a learning experience that I am happy to be apart of for my own future so I certainly appreciate your responses.