Technology Service Provider Contracts

Understanding the increasing dependence that financial institutions have on technology service providers, bank regulators have ramped up their efforts to require banks to appropriately handle third-party risk management. The Federal Deposit Insurance Corporation (FDIC) has identified gaps noted by some examiners regarding several technology service provider contracts that were inadequate under existing guidance. These contracts were missing or inadequately addressed key provisions, such as:

  • Requiring the service provider to maintain a business continuity plan,
  • Lacking standards for data recovery along with appropriate remedies when a recovery standard is missed.
  • Defining key terms in the contracts relevant to business continuity and/or incident response.

Contracts lacking these provisions violate the Interagency Guidelines Establishing Information Security Standards, as promulgated under the Gramm-Leach-Bliley Act.

Vendors that provide technology-related services can create special risks for depository institutions that must be properly addressed in their service contracts. The FDIC indicated that it plans to hold boards and senior management of financial institutions accountable for controlling those risks, in accordance with the requirements of the law and its existing regulatory guidance.

Financial Institutions should be willing to hold their service providers accountable and negotiate an appropriate contract. All financial institutions should have provisions that they review for all of their contracts, along with a robust vendor management program that will help uncover any weakness in business continuity and data recovery early in the process.

Strunk at WBA’s Education Summit & Regulatory Compliance Conference

Strunk is excited to be exhibiting once again at the Western Bankers Association’s Education Summit & Regulatory Compliance Conference next week, August 25th-28th. This year hosted at the Hyatt Regency Huntington Beach, the event always proves to have many learning opportunities for bankers to gain insight into the most current information facing our industry.

In addition to visiting with many current clients, we look forward to showing attendees the latest features offered by our Governance, Risk Management and Compliance (GRC) software. The solution now includes six GRC tools – Risk Assessor, Policy Manager, Controls Manager, Skills Manager, Issues Manager and the all new Vendor Manager.

Vendor Manager provides an easy to follow standardized process to assess risk, gather due diligence materials, evaluate contracts and stores all vendor documentation in one convenient place. Vendor Manager keeps everything organized, is simple to use and of course follows the latest FFIEC guidelines.

Please stop by booth 28 to learn how to improve compliance, streamline responses, and enhance collaboration… all with less effort. All bankers will also have the opportunity to enter to win a $250 Amazon gift card from Strunk. We can’t wait to see you!

Latest ODP Manager Enhancements

At Strunk, we are committed to providing best-in-class software solutions, and are constantly providing enhancements that we feel will best serve our clients. This month we are pleased to announce the addition of ODP Manager Dashboard within our industry-leading overdraft management application, ODP Manager.

ODP Manager clients will now be able to see their performance over time, as well as in comparison to our entire customer base, for five key indicators: Percent with Limit, Percent Opt In, Overdraft Fee, Consumer Overdraft Limit, and Business Overdraft Limit. The dashboard will graphically display the organization’s performance in purple as compared to the 25th, 50th and 75th percentile statistics for our entire client base. The Dashboard will also display the organization’s monthly trend for Percent with Limit and Percent Opt In.

Each quarter we will email clients a summary of their performance, along with tailored recommendations to address areas that may need attention. We believe the new ODP Dashboard will help clients more effectively monitor overdraft program key indicators and improve performance over time.