The CFPB expressly stated that a company could utilize outsourced or external compliance staff. The key is that the compliance personnel have the aptitude and experience to be able to institutionalize compliance and ensure that the lender is in a position of being able to identify and correct problems before they arise. The critical element, therefore, is having a combination of industry experience, a working knowledge of the ever-changing regulations and industry standards, and the know-how to implement and monitor new procedures in a way that will cause every employee to realize the need to consider compliance at all times. Hence, it's far more important to have the combination of skills as opposed to physical contact. In other words, it's less difficult to find people who can carry out a compliance strategy as opposed to developing and amending that strategy as needed.