Solutions · Assurance · NCBA CTS
The CTS program gives creditor firms and financial institutions confidence that their law firms and vendors meet the highest security standards.
Premier Security program
Our annual assessment is built around the expectations of regulators, creditors, law firms, and vendors. It reflects how today's financial and regulatory environment actually works. The difference shows up in how the findings are interpreted, how remediation is priortized and how reports land with stakeholders reading them.
01 · Provenance
Convergent worked with the National Creditors Bar Association to develop the Committed to Security framework. The assessment evolves alongside the regulatory landscape, ensuring it remains relevant, aligned with current expectations, and defensible year after year.
02 · Standing
The Convergent CTS report is a familiar artifact at the major creditor clients evaluating your firm. Familiarity reduces friction. Friction reduces deal flow.
03 · Continuity
CTS is annual; the security posture has to be defensible year-round. Sanctum holds your evidence, tracks remediation, and supports the questions creditor clients ask between cycles.
What the assessment covers
The CTS framework spans multiple risk and control domains tailored to the operational realities of creditor industry vendors — including consumer information risk, AI-related security, vendor operations, physical security, information security, and privacy and regulatory compliance. Convergent's assessment delivers the complete questionnaire scope in one engagement.
Domain 01
How your firm handles Consumer Non-Public Information (NPI) and confidential data across the vendor relationship. Storage, processing, transmission, and monitored versus unmonitored consumer interaction — the program's central scoping lens for assessing vendor risk to creditor clients.
Domain 02
Regulatory alignment with FDCPA, GLBA, and state privacy laws. Vendor management. Consumer-facing privacy practices and the documented evidence to defend them.
Domain 03
Operational controls and oversight specific to creditor industry vendors. Day-to-day practices for managing vendor operations, change management, business continuity, incident response, and audit readiness — the operational discipline that determines whether a vendor can deliver under regulatory and creditor-client expectations.
Frequently asked
Most CTS engagements run 6 to 10 weeks from kickoff to final report. Firms going through their first assessment run longer; firms in a renewal cycle with Sanctum-tracked evidence run shorter.
Convergent is the NCBA program partner. Other firms can assess against the framework, but Convergent's role spans framework stewardship, assessment delivery, and continuous client support — a different relationship than a third-party assessor.
You receive a CTS assessment report suitable for sharing with creditor clients during procurement and onboarding. Sanctum carries your evidence and remediation tracking forward to the next annual cycle.
Yes — that is its purpose. The Convergent CTS report is designed for creditor-client procurement review and is a recognized artifact among major creditor clients.
Fixed-fee per annual cycle, scoped against your firm's size and complexity. The scoping call is free and produces the proposal. Multi-year arrangements are available.
Ready when you are
The first conversation is with a senior manager who has worked the CTS program directly. Bring your context; leave with a scoped proposal.