Due Diligence and Ongoing Monitoring

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  • 1.  Signature guarantee/Medallion STAMP

    This message was posted by a user wishing to remain anonymous
    Posted 11-13-2023 01:54 PM
    This message was posted by a user wishing to remain anonymous

    Do you classify this type of service provider as a "vendor"?  I am getting conflicting information on whether they should/would be considered a vendor.



  • 2.  RE: Signature guarantee/Medallion STAMP

    This message was posted by a user wishing to remain anonymous
    Posted 11-14-2023 09:00 AM
    This message was posted by a user wishing to remain anonymous

    Hopefully this excerpt from the Interagency Guidance answers your question:

    "A third-party relationship may exist despite a lack of a contract or remuneration. Third-party relationships can include, but are not limited to, outsourced services, use of independent consultants, referral arrangements, merchant payment processing services, services provided by affiliates and subsidiaries, and joint ventures."  (page 30)




  • 3.  RE: Signature guarantee/Medallion STAMP

    This message was posted by a user wishing to remain anonymous
    Posted 11-24-2023 10:13 AM
    This message was posted by a user wishing to remain anonymous

    We consider them out of scope vendor, and we don't conduct a due diligence.

    Is this correct? should we do our due diligence? What do we ask/request?