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Re: Hedgebunny post# 105747

Friday, 10/21/2016 4:16:37 PM

Friday, October 21, 2016 4:16:37 PM

Post# of 235174
Take your pick from problems with a vendor review of sfor for financial institutions performed by the FDIC. Full guidance can be found Here


Here are some of the bulletin topics for vendor reviews. Do you think SFOR would pass the smell test on these?


Audited financial statements, annual reports, SEC filings, and other available financial indicators.

Significance of the proposed contract on the third party's financial condition.
Experience and ability in implementing and monitoring the proposed activity.
Business reputation.
Qualifications and experience of the company's principals.
Strategies and goals, including service philosophies, quality initiatives, efficiency improvements, and employment policies.
Existence of any significant complaints or litigation, or regulatory actions against the company.
Ability to perform the proposed functions using current systems or the need to make additional investment.
Use of other parties or subcontractors by the third party.
Scope of internal controls, systems and data security, privacy protections, and audit coverage.
Business resumption strategy and contingency plans.
Knowledge of relevant consumer protection and civil rights laws and regulations.
Adequacy of management information systems.
Insurance coverage.



Evaluate the overall effectiveness of the third-party relationship and the consistency of the relationship with the financial institution's strategic goals.
Review any licensing or registrations to ensure the third party can legally perform its services.
Evaluate the third party's financial condition at least annually. Financial review should be as comprehensive as the credit risk analysis performed on the institution's borrowing relationships. Audited financial statements should be required for significant third-party relationships.
Review the adequacy of the third party's insurance coverage.
Ensure that the third party's financial obligations to others are being met.
Review audit reports or other reports of the third party, and follow up on any needed corrective actions.
Review the adequacy and adherence to the third party's policies relating to internal controls and security issues.
Monitor for compliance with applicable laws, rules, and regulations.
Review the third party's business resumption contingency planning and testing.
Assess the effect of any changes in key third party personnel involved in the relationship with the financial institution.
Review reports relating to the third party's performance in the context of contractual requirements and performance standards, with appropriate follow-up as needed.
Determine the adequacy of any training provided to employees of the financial institution and the third party.
Administer any testing programs for third parties with direct interaction with customers.
Review customer complaints about the products and services provided by the third party and the resolution of the complaints.
Meet as needed with representatives of the third party to discuss performance and operational issues.

I've put in bold a few that I think would be serious issues. Now if someone goes over the full guidance I think they will get why sfor is not ready for the financial industry just yet.
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