Policy, Program and Procedures

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  • 1.  Bank Service Company Act -

    Posted 02-22-2023 11:07 AM


    I am curious how other institutions measure third party services and if they need to be reported to the FDIC. Does anyone have a best practice that has proved to be consistent and aligned with the requirement? 

  • 2.  RE: Bank Service Company Act -

    Posted 02-22-2023 11:24 AM

    Covered services requiring reporting under BSCA include: check and deposit sorting/posting, computation/posting of interest, preparation/mailing checks/statements, other clerical, book keeping, accounting, statistical or similar functions, data processing, internet banking or mobile banking services.

    We added a check in our new vendor onboarding process and will recommend to a relationship owner that notification be provided if we think the services fall within the above however, compliance owns the ultimate responsibility for the reporting.  

    Since Third Party Risk is reviewing all new relationships, we felt like although we don't own the responsibility for the reporting that we can provide an important control to help mitigate the compliance risk.

    I am interested to hear how others are managing this one.  We have found its a little like hot potato, no one wants to own the responsibility. Our regulators have been OK with our process, no recommendations.

    Shelly Chase
    VP Operational Risk

  • 3.  RE: Bank Service Company Act -

    Posted 02-22-2023 12:08 PM

    To clarify, we are familiar with the act and the standard required services, just wondering how others navigate all the various services, that are not so clear.


    Thank you,


    Jeremy Pelkey, CRVPM [he/him/his]

    Assistant Vice President

    Information Security Analyst


    Bangor Savings Bank