OCC, FDIC Enforcement Action Targets Vendors’ Risk Management


On January 17, the OCC released a cease and desist order entered jointly by the OCC and the FDIC with two affiliated technology service providers that offer payment and other technology solutions for banks. Without describing the specific circumstances leading to the action, the order states that the regulators had reason to believe the service providers were operating without (i) an internal auditor or an integrated risk-focused audit program; (ii) a comprehensive due diligence program or formal policies to evaluate vendor risk; (iii) an enterprise-wide risk assessment; (iv) effective business continuity or disaster recovery planning; (v) procedures to identify software vulnerabilities; and (vi) an effective log review program to identify threats. The regulators did not assess a penalty, but will require the vendors to implement numerous risk management enhancements. Under the order, the technology service providers or their board must, among other things, (i) fill specific management positions; (ii) implement an audit program; (iii) conduct a security risk assessment; (iv) develop a vendor management program; (v) implement business continuity/disaster recovery plans; and (vi) submit quarterly progress reports to regulators and client banks.

Topics:  Banks, Enforcement Actions, FDIC, OCC, Risk Management, Vendors

Published In: Finance & Banking Updates, Science, Computers & Technology Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© BuckleySandler LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »