Oversight of Service Providers
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: Our credit cards are issued by a third party. We don't do the underwriting and the accounts are not on our balance sheet; our name is on the card and we receive fee income from the third party. What, if any, is our obligation in relation to oversight of service provider relationships?
Answer: It appears that your institution is a "service provider" for the card issuer. You collect the application for the card issuer. There are several red flags related to taking the application. The card issuer should contact you to assure that you have an adequate program in place to perform the duties related to identity theft red flags.
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