Due Diligence and Ongoing Monitoring

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  • 1.  FRB/FHLB

    Posted 04-01-2020 04:50 PM
    Do you consider FRB and FHLB to be vendors?


  • 2.  RE: FRB/FHLB

    Posted 04-01-2020 05:26 PM
    Yes, but we exempt them from oversight.  Our auditors were comfortable with this approach.
    Original Message


  • 3.  RE: FRB/FHLB

    This message was posted by a user wishing to remain anonymous
    Posted 04-02-2020 09:40 AM
    This message was posted by a user wishing to remain anonymous


    I would assume other GSEs (FNMA, FHLMC) would be the same- vendors but exempt?  What about other FIs you deal with via secondary market?
    Original Message


  • 4.  RE: FRB/FHLB

    Posted 04-02-2020 05:53 PM
    How do you word your exemption or what is your reasoning for exemption?
    Original Message


  • 5.  RE: FRB/FHLB

    This message was posted by a user wishing to remain anonymous
    Posted 04-03-2020 09:07 AM
    This message was posted by a user wishing to remain anonymous

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    • Exempt – any third party with a contract of one year or less without renewals. Exempt also includes real estate leases, regulatory agencies, government sponsored entities (GSEs), credentialing bodies/agencies, attorneys, 4th parties (Vendor Subcontractors), and a growing list of specialized Non-Traditional Third Parties. An otherwise qualifying Third Party may be made Exempt through the exception process if the Third Party: (1) Classification is Level 1, (2) has no direct access to Customer or Confidential data, (3) does not interact with customers, and (4) has no transactional involvement. Service providers that have access to sensitive data (customer lists, addresses, NPI) will still be required to have appropriate confidentiality and customer information safeguarding agreements.

    Original Message