Regulations

Outside of the standard form provided by the FDIC in FIL 49-99 does anyone have a template letter that they provide to their regulators as notification for new vendors?

Also is there a more updated list of the services that are required to be reported under the act? Something that includes more technical services?

Hi there,

Regarding technical services, the FDIC provided the following letter in April 2019. The letter updates the general types of services subject to the notification requirement under the Bank Services Company Act.

Technology Service Provider Contracts

Unfortunately, the letter contains more information about technical providers but would not be considered an exhaustive list.

Here is the specific text

Section 7 of the Bank Service Company Act (Act) (12 U.S.C. 1867) requires depository institutions to notify, in writing, their respective federal banking agency of contracts or relationships with technology service providers that provide certain services. Services covered by Section 3 of the Act include check and deposit sorting and posting, computation and posting of interest, preparation and mailing of checks or statements, and other clerical, bookkeeping, accounting, statistical, or similar functions such as data processing, Internet banking, or mobile banking services.

I hope that is helpful, and I would love to hear from other members on the subject.

Original Message:
Sent: 12-28-2021 01:05 PM
From: Stephanie Bowersox
Subject: Back Service Company Act Section 7

Outside of the standard form provided by the FDIC in FIL 49-99 does anyone have a template letter that they provide to their regulators as notification for new vendors?

Also is there a more updated list of the services that are required to be reported under the act? Something that includes more technical services?

Original Message:
Sent: 1/5/2022 11:49:00 AM
From: Hilary Jewhurst
Subject: RE: Back Service Company Act Section 7

Hi there,

Regarding technical services, the FDIC provided the following letter in April 2019. The letter updates the general types of services subject to the notification requirement under the Bank Services Company Act.

Technology Service Provider Contracts

Unfortunately, the letter contains more information about technical providers but would not be considered an exhaustive list.

Here is the specific text

Section 7 of the Bank Service Company Act (Act) (12 U.S.C. 1867) requires depository institutions to notify, in writing, their respective federal banking agency of contracts or relationships with technology service providers that provide certain services. Services covered by Section 3 of the Act include check and deposit sorting and posting, computation and posting of interest, preparation and mailing of checks or statements, and other clerical, bookkeeping, accounting, statistical, or similar functions such as data processing, Internet banking, or mobile banking services.

I hope that is helpful, and I would love to hear from other members on the subject.

Original Message:
Sent: 12-28-2021 01:05 PM
From: Stephanie Bowersox
Subject: Back Service Company Act Section 7

Outside of the standard form provided by the FDIC in FIL 49-99 does anyone have a template letter that they provide to their regulators as notification for new vendors?

Also is there a more updated list of the services that are required to be reported under the act? Something that includes more technical services?