All the federal regulatory agencies have clear expectations around banks’ vendor management programs. Required elements include review of contractual arrangements, identification of critical vendors, continuous and independent reviews, and risk assessments. As well, a review of the compensation arrangements between the bank and its vendors are at issue. Is your program up to these expectations? Make sure you have the proper responsibilities and accountability articulated for your program.
- Who Should be the Focus of Your Vendor Program?
- Concerns/guidance from each Federal Regulator (CFPB, Federal Reserve, and OCC)
- Board & Management Oversight of Regulatory Expectations
- Service Level Agreement (SLA) Recommendations
- Policies and Procedures, Training, and Auditing
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