Policy, Program and Procedures

Hello,

I am the Director of Vendor Risk Management for a community bank. I am curious how others treat the following vendors. Are they included in your vendor database? Do you perform due diligence on them when onboarding?

1. Appraisers
2. Title Companies
3. Organizations that partner with your Corporate Giving Team

Thank you!

Yes, we include them in our vendor system and perform due diligence on them when onboarding. We do this for "Tracking" purposes only. They also appear on our quarterly and annual reports.

I hope this information helps.

Thanks.

Yes, we vet at onboarding and maintain records in our database.

1. Appraisers - We utilize our 3rd party to vet appraisers and maintain a "Bronze" level or low risk. They are provided borrower names and addresses so we determined it was important to protect our customers at this level.
2. Title Companies - We utilize our 3rd party vet title companies and maintain a "Bronze" level or low risk rating. We do share wiring instructions for transactions in addition to borrower details. We manually verify wiring instructions before transactions.
3. Organizations that partner with your Corporate Giving Team - We vet them prior to a transaction then maintain an "Administrative" risk after. This allows us to catalog their data in addition to setting reminders to review every 24 months OR at the time of change/incident after implementing. The review includes an OFAC Sanctions Search.