Due Diligence and Ongoing Monitoring

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  • 1.  SEC Action Against Vendor

    This message was posted by a user wishing to remain anonymous
    Posted 11-14-2023 09:24 AM
    This message was posted by a user wishing to remain anonymous

    Our CU recently discovered that a new vendor has a government action to pay a penalty to settle SEC Charges that it provided misleading account statements to investors.

    Do any of you have procedures or a waiver in connection with continuing with such a vendor? 

    We are not using the particular service that is subject to the action. 



  • 2.  RE: SEC Action Against Vendor

    This message was posted by a user wishing to remain anonymous
    Posted 11-14-2023 02:32 PM
    This message was posted by a user wishing to remain anonymous

    We don't have specific procedures in place but we would thoroughly assess the situation and consider things like how long ago did this occur? What was the nature of the issue? Are the guilty parties still involved with the company? How critical is the vendor? What were the results of our internal due diligence?  

    Curious how you found out . . .  




  • 3.  RE: SEC Action Against Vendor

    This message was posted by a user wishing to remain anonymous
    Posted 11-14-2023 02:47 PM
    This message was posted by a user wishing to remain anonymous

    Thank you!

    I believe the dept head went back through the assessment and that is how we found that it is not the service we are using, thankfully. However, your checklist is quite helpful! 

    It was discovered via a BBB Check.