Due Diligence and Ongoing Monitoring

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  • 1.  Report of Examination

    This message was posted by a user wishing to remain anonymous
    Posted 01-29-2024 08:01 AM
    This message was posted by a user wishing to remain anonymous

    Hello,

    How would we know which of our vendors are examined by regulators. 

    For example, could we request a ROE from FDIC, and if they don't conduct examination on that particular vendor, they would just tell us? Is there a any other way to find out? 

    Which of your vendors do you request the ROE?

    Any input would be appreciated.



  • 2.  RE: Report of Examination

    Posted 01-29-2024 08:45 AM

    Typically vendor (TSP) exams are conducted by joint exam teams from representative FFIEC agencies.  This is done (through a proccess not all that transparent) in response to financial institution filing under the BSCA requirement.  When some 'critical mass' of filings reaches a point of material interest to regulatory and exam is conducted.
    To obtain a copy of an ROE, the financial institution must request the ROE from their primary regulator.  This confidential information is protected by law (up to and including criminal penalties).  In a past role, I simply presented a roster of what my bank considered to be critical service providers and my regulator provided the ROE artifacts for the vendors that had been performed.



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    L. Beachy
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  • 3.  RE: Report of Examination

    Posted 01-29-2024 08:54 AM

    To be examined by regulators vendor would need to be a SSP (significant service provider) or TSP (technology Service provider).  We contact our regulator in writing, for us its the FDIC, directly on an annual basis and request ROE's for all vendors we know are examined.  We also submit a listing of new vendors added since the last request and ask if any of our new vendors are examined.  We track as part of our vendor inventory if a vendor is a FFIEC TSP or SSP.

    We use some I will say basic common sense when we submit our listing of new vendors to the FDIC to see if they are examined as a SSP or TSP.  FFIEC resources are finite so vendors that are smaller, not providing significant services in financial services arena we generally don't include.  Your regulator will want a copy of your contract for any of your vendors that are a TSP or SSP and you will only be eligible for ROE's performed after your contract effective date.

    Your core provider(s) are definitely examined so ask for those.  I would then work through your critical or significant technology services vendors and ask about those.  In my experience the FDIC is willing to work through a reasonable listing and let you know which vendors are examined.  



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    Shelly Chase
    VP Operational Risk
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