Compliance

Simple Things to Lower Your Vendor Management Program Risk Profile

I recently conducted a Vendor Management Program Audit and Risk Assessment as a part of our Advisory Services for a midsize financial institution. Performing both gives you a more complete picture of where the institution is at and helps document current state, desired state, gap analysis and create a prioritized road map for a healthier program. This particular [...]

2017-10-20T08:04:48+00:00 October 20th, 2017|3rd Party Risk, Audit, Compliance, Risk, Vendor Management|0 Comments

3rd Party Breaches – Are YOU Reaching Out to Your Customers/Members?

Okay, the Equifax breach wasn't your fault. Neither was the Home Depot breach, Target breach, etc., etc. Thus, the Data Breach Notification regs don't apply to you so you're clear of any responsibility. Or are you? I scoured a couple hundred bank and credit union websites this weekend and found that very few provided any information [...]

3rd Party Code of Conduct as a Contractual Condition for Termination

While most companies have Code of Conduct for staff, not as many require their 3rd parties to sign such a document. Even fewer include violation of that Code of Conduct as a condition for cancellation of contract. As we all know, being associated with a 3rd party that has received adverse attention in the media could [...]

2017-10-20T08:18:32+00:00 September 22nd, 2017|3rd Party Risk, Compliance, Governance, Risk, Vendor Management|0 Comments

Referrals and Breach Notification Requirements

I've recently been asked whether a financial institution has Breach Notification responsibility in the case where the institution refers customers to vendors such as financial service providers where the institution merely vetted several vendors as a convenience for its customers, has no contract with the vendors, passes no PII/NPPI to the vendor, receives no referral fees [...]

2017-03-16T12:43:13+00:00 February 8th, 2017|3rd Party Risk, Audit, Compliance, Vendor Management|0 Comments

You’re Not Too Small for Multiple Lines of Defense

Classic risk management employs 3 lines of defense. But there's also a possible 4th line when it comes to regulatory issues, specifically vendor management. Please note that I have seen multiple titles that fit the roles below so don't get hung up on the titles. If you're a smaller institution and you wear multiple hats, you [...]

Are your vendors delivering value beyond just meeting SLA’s? How are you measuring their value?

How do you measure your vendor's value?  s vendor management programs mature, we need to understand the value a vendor delivers beyond meeting its Service Level Agreements. While we frequently outsource significant functions (critical and high risk) because a vendor can help us meet our strategic goals, including doing something better/faster/cheaper, what else are we obtaining [...]

So many SOC’s to review, so little time and staff to go around. Here’s a crash course:

Crash course here: http://bit.ly/1Oobnan Everyone is heavily overburdened with the demands of trying to comply with regulations. So if your IT or Info Security team doesn't have enough staff to review all SOC reports (or possibly just reviews those with exceptions) yet your internal audit dept wants proof that reviews of all SOC reports are conducted, [...]