This message was posted by a user wishing to remain anonymous
Recently we had an external auditor, write up a finding in regard to Escrow and Title companies Due Diligence. They said that because of Regulatory guidance from 2023, we should include any business arrangement between a banking organization and another entity, by contract or otherwise in our inventory of vendors to review.
Up to this point our vendor management has not included the escrow and title companies in our "in scope vendors".
So, my question is whether we should, and if yes, what type of review should we conduct on an ongoing basis, especially since it could be several months or even years in between when a particular escrow or title company is going to be used. Should we review their financials, SOC report (if any), BCP, employment practices, etc.? And also, should this be done by vendor management or business units?
Any input would be greatly appreciated.
-------------------------------------------