Policy, Program and Procedures

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  • 1.  Bank Service Company Act (BSCA)

    Posted 08-07-2023 01:10 PM

    Happy Monday! I am struggling with the BSCA reporting and hope some of you can help me out. I have read Section 3 of the BSCA so many times, but am inquiring as to exactly what you all are reporting. There are obvious third parties that make changes to posting, computation, etc. The next part is for "preparation and mailing of checks, statements, notices and similar items". I read this as it could apply to title companies paying the purchaser for a house closing, marketing companies who send money out for promotions, services that pay insurance or taxes for our customers, attorneys making payments to someone for a lawsuit, gift card & travel card, payment processors who make electronic payments for our customers (Visa, NACHA, etc.). Lastly, I'm thinking that CDARS & ICS could fall under the "clerical, bookkeeping, accounting..." part of the act. 

    I would appreciate any guidance that you can provide. This one is just not clear to me at all. Thank you!!

    Tina O'Donnell, AAP, CCBRS    

    VP Operational Risk Manager



  • 2.  RE: Bank Service Company Act (BSCA)

    Posted 08-08-2023 08:40 AM

    Hi Tina!

     

    I work for a financial institution, and recently was working with dissecting this and trying to reconcile similar questions.  I ended up setting up a call with our local FDIC representative, and he was very helpful in giving some insight!  What I ended up doing was sending him a listing of third-parties I thought would fit the mold, and he sent it over to their team.  They gave me some feedback on what would be best to report (based on usage).  The FDIC team said that there is no penalty if we send more (but obviously it's more work on our end).

     

    We submitted for the following types of services, which I hope is helpful to you!  I'm sure this is not exhaustive depending on what everyone uses, but it was at least a solid start here!

    • CECL model vendor
    • Residential loan origination/underwriting/disclosure vendor
    • Lockbox services vendor
    • Mobile banking vendor
    • Remote deposit vendor
    • Open and fund vendor
    • Internet banking vendor
    • Bill payment vendor
    • Accounts payable platform vendor
    • Core operating system vendor

     

    We also will be starting to use CDARS ICS, and I am planning to submit that under the same rationale you mentioned, once we have the signed contract.

     

    Thanks for reaching out!!

    Tracey

     

    With care,

    Tracey Lynne Campbell

    Third Party Risk Analyst | Fidelity Bank


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