Skip to content
BOL Conferences
Thread Options Tools
#2007355 - 04/10/15 03:14 PM On-Site Reviews of Critical Vendors
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
I have been out of this loop for over 10 years and am in need of some guidance.

We have been advised by the FDIC that we need to do on-site inspections of our critical vendors. For vendor managment purposes we have identified 20 or so critical vendors and management is concerned about the expenses involved with doing these on-site reviews.

I would like to hear from those of you that are doing on-site reviews. Which vendors are you visiting and what are you doing during these visits? Do you take a questionnaire or checklist with you? Do you find that the vendors are willing to let you on-site?

Any advice is greatly appreciated!
_________________________
TryingToComply
CRCM

Return to Top
General Discussion
#2007502 - 04/10/15 07:04 PM Re: On-Site Reviews of Critical Vendors TryingtoComply
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
We do not conduct on site visits of critical vendors and it's never been suggested we do. Our core processor though, our CEO is Chairman of the Board and is there on-site for meetings all the time and many of attend training sessions there.

Return to Top
#2007513 - 04/10/15 07:27 PM Re: On-Site Reviews of Critical Vendors TryingtoComply
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
I have never heard of such a ridiculous blanket recommendation. I would be having your CEO call the regional supervisor directly and ask them to please provide in writing a little clarification regarding the basis of this recommendation. I would start with some basic questions, such as: Is there a problem with your current due diligence process? How do they define critical vendor? For vendors that provide services based on redundant or distributed systems, which cite would they like you to visit? Just exactly, when conducting a cite visit, what would they recommend that you review and document so that you can provide the information in a report format they are seeking on their next visit. Etc.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2007571 - 04/12/15 01:18 PM Re: On-Site Reviews of Critical Vendors TryingtoComply
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
I agree! TTC, the critical vendors, for the most part will be fairly large with detailed back-up and recovery procedures of their own. By necessity, many will have multiple sites, scattered around the US, and potentially the world. How is a visit to a site (headquarters, underground recovery, secret back-up hot site) supposed to help the bank.

Their management will most likely not even allow someone into their critical areas, and how would a site visit enhance the bank's knowledge, other than to ensure that a building (named or unnamed) is secure. I believe your regulator is well intentioned but totally out of the loop, or misunderstood.

If FDIC insists, volunteer to visit the vendor's Hawaii location during the winter months.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2015939 - 05/26/15 03:20 PM Re: On-Site Reviews of Critical Vendors TryingtoComply
athomas@bankcsb.com Offline
Junior Member
athomas@bankcsb.com
Joined: Sep 2013
Posts: 28
Midwest
I volunteer to visit Hawaii during the winter months smile

Return to Top
#2015941 - 05/26/15 03:29 PM Re: On-Site Reviews of Critical Vendors TryingtoComply
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,858
Pulling people out of the ditc...
we have done on-site visits to vendors when performing due diligence when assessing new business with them, but as far as ongoing on-site for reviewing critical on a recurring basis, not going to happen. We'll perform our annual review, annual DR certification, and would only go on-site if we thought there were some significant issues. Have never had a regulator question our process or tell us we needed to do it.
_________________________
Providing alternative truths since the invention of time

Return to Top