Due Diligence and Ongoing Monitoring

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  • 1.  Brokered Deposits Vendors

    Posted 20 days ago

    We are onboarding our first Brokered Deposits vendor since before the 2024 SVB, et al collapse. What due diligence do you gather from these types of vendors? Our last onboarding was very long time ago and the previous vendor program manager treated them as financial institutions.



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    Nicole Keefe
    SVP, Enterprise Risk Manager
    Risk Management Department

    445 Pine Avenue, Goleta, CA 93117
    Office Phone: 805-690-3255 | Cell Phone: 805-452-0379
    Email:nicole.keefe@communitywestbank.com
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  • 2.  RE: Brokered Deposits Vendors

    Posted 18 days ago

    Good afternoon,

    There are several factors to consider in this instance. While the specific requirements may vary depending on your risk methodology, based on the description provided-and assuming the service provider will have access to Non-Public Information (NPI)-I recommend obtaining the following documentation:

    • SIG Questionnaire
    • SOC 2 Type II Report
    • Business Continuity Plan / Disaster Recovery Plan
    • Financial Statements
    • Certificate of Insurance
    • W-9
    • Non-Disclosure Agreement (NDA)
    • Executed Contractual Agreement
    • AI Governance Documentation