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  • 1.  TSP Report of Examination Disclosure Statement to Board Members

    Posted 12-16-2019 02:23 AM
    ​When I requested our critical vendors most recent examination reports, the FDIC provided the below "note" to be disclosed to our board. I was wondering if anyone else has been given this same "note"? If so, can someone provide clarity about what that disclosure statement is for and the context? Answering more concisely, "Why is the Board looking at that statement?"

    Subject: Information Technology Report of Examination Members of the Board:

    Your bank requested one or more Technology Service Provider Reports of Examination for which you are a client. The requested Report(s) of Examination is(are) enclosed. If a requested Technology Service Provider Report of Examination is not included, the service provider is not examined regularly by the FDIC or FFIEC.

    Basis of Evaluation: In evaluating the operations of these servicers, we depended upon the following sources of information:

    1. Records and books of the servicer.
    2. Statements made by the servicer's directors, officers, and employees.
    3. Other sources believed to be reliable and presumed correct. This evaluation does not diminish direct audit responsibilities of institutions serviced by this organization.
    Confidentiality Notice: The information contained in the evaluations is confidential and cannot be disclosed or made public in any manner. Notify us immediately if you receive a subpoena or other legal process document, which calls for the production of this evaluation. 


  • 2.  RE: TSP Report of Examination Disclosure Statement to Board Members

    Posted 12-16-2019 09:28 AM

    Re Colleen Jewell-Suiter's post:

    Interesting.   I have never received the "note to be disclosed to the board" you provided.

     When I request and receive an IT-ROE from the OCC, the following statement is included in the email:

     This ROE remains the property of the OCC and is provided to you as a courtesy and useful tool in your vendor management process.  These ROEs are confidential, and you should only share them with officers, employees or those professionals under contract with the bank.  Failure to comply with these confidentially rules can subject you and your bank to penalties under Section 641 of Title 18 of the U.S. Code.

     Please acknowledge receipt of the attached Report of Examination and notice of the above confidentiality covenants by responding to this email. 

     




  • 3.  RE: TSP Report of Examination Disclosure Statement to Board Members

    Posted 12-17-2019 09:31 AM
    This is very interesting - I've never requested an IT-ROE report.  How can I learn more?


  • 4.  RE: TSP Report of Examination Disclosure Statement to Board Members

    Posted 12-17-2019 09:58 AM
    ​Reach out to  your OCC regulator.  They can provide the contact info for you to request IT-ROE via OCC secure email.  You must be registered as a customer of the vendor at the time of the review to receive the open section of the report (i.e., if  you're reviewing a potential vendor relationship,  you can't get the report.  Only available to customers of record)

    Rosalie Stremple
    MS-MIS, CTPRP, CBCP


  • 5.  RE: TSP Report of Examination Disclosure Statement to Board Members

    Posted 12-18-2019 09:20 AM
    I have found the TSP reports to be very helpful in finding out if the vendor has any real problems in their IT controls structure.  The regulatory bodies involved really do a great job in these exams.

    For the OCC, send your request to SDTSPrequest@occ.treas.gov

    For each vendor, you need to include the following:​
    • Bank name, city, and state requesting the ROE copy
    •  Name, title, and address of person requesting the ROE copy
    •  SP name, city, and state
    •  Brief description of core products or services provided by the SP
    •  Contract date
    •  If applicable, date of the last SP report we provided to the bank 

    My experience is that it takes a while for anyone to respond to the request - as long as 2-3 months.  Good luck!


  • 6.  RE: TSP Report of Examination Disclosure Statement to Board Members

    Posted 12-18-2019 09:31 AM
    ​The other 'downside' to these ROE documents is that it takes a while before a vendor shows up on the regulators radar of FFIEC agencies.  Most of that is due to the fact that even the various agency resources (examination time) are stretched very thin, but the other factor is that many financial institutions are lax in their obligations to report the use of outside firms under the Bank Service Company Act (1999).  It is only after the number of clients accumulates to a threshold level that the FFIEC agencies will consider scheduling an actual regulator TSP exam.
    Bank Service Company Act
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    Bank Service Company Act
    Section 7 of the BSCA requires depository institutions to notify, in writing, their respective federal banking agency of contracts or relationships with service providers that provide certain services. Services covered by the Act include check and deposit sorting and posting, computation and posting of interest, preparation and mailing of checks or statements, and other clerical, bookkeeping, accounting, statistical, or similar functions.
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    L. Beachy
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