Due Diligence and Ongoing Monitoring

Hi everyone,

I'm curious to know if other financial institutions are actively monitoring the Federal Reserve. Our credit union has done so since the inception of our TPVM program, but I've been finding it increasingly difficult to access the information we need.

This has led me to question whether this level of monitoring is still necessary, especially considering that we wouldn't be able to operate without the Fed regardless.

I'd really appreciate hearing how others are approaching this. Is this something your institution prioritizes? Any insights or experiences would be greatly appreciated.

Thank you

We monitor them - as best we can.  They provide very little information that we can actually use as part of our VM program.  I'm kind of like you, it is what it is.

We have government agencies and regulatory bodies carved out of scope for our TRPM, and while not totally encompassing of all facets of the Fed, we have excluded the Fed from our monitoring and have not had anyone challenge it thus far. I would be interested to learn if anyone else has had a different experience.

The Federal Reserve is a government agency so practical options to manage third-party risks related to them are incredibly limited. Additionally, there is no contractual relationship with the Fed. For those reasons, we consider them to be exempt from TPRM monitoring. We do, however, perform an annual risk assessment on them.

Our board-approved Vendor Management policy de-scopes vendors over which we have no influence.  This includes utilities, credit bureaus, and the Federal Reserve.  They are all critical (that is, impact would be significant without them) but have a low risk likelihood.

We are updating our TPRM policy to add "Relationships with government agencies, taxing authorities, regulatory bodies, and courts" will be excluded from the policy.