Latest Publications


The UDAAP Trap: How Financial Institutions can Avoid Penalties when Using Third Party Services

In Part 1, we noted that financial institutions could find themselves potentially liable for committing an alleged Unfair, Deceptive, or Abusive Act or Practice (UDAAP) as a result of the actions of certain types of external...more

6/11/2014 - Banks CFPB Enforcement Enforcement Actions Third-Party Risk UDAAP

Subcontracting in the Cloud

The rise of cloud computing services and the privacy/security issues involved have been much discussed. But when customers procure cloud-based services, a critical "behind the scenes" issue is often overlooked: is the cloud...more

6/26/2013 - Cloud Computing Cybersecurity Software Subcontractors Supply Chain Third-Party

Downselect with Care: Managing a Critical Juncture in the Sourcing Process

The timelines of most strategic IT or sourcing projects are punctuated with key moments that can make or break the deal. These include defining the customer's strategic objectives, determining which suppliers will be asked to...more

12/10/2012 - Outsourcing

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