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#2228683 - 01/09/20 08:56 PM Vendor Management/OCC
OliviaG2014 Offline
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Joined: Jan 2020
Posts: 21
Sorry guys I know I have been asking a lot from you all recently but I changed banks and regulators so I'm a little discombobulated lately!

My new bank has never heard of the "Notification of Performance of Bank Services" form that the FDIC requires for critical vendors. For you OCC regulated banks, is this not required?

Also, they don't have a consumer complaint log and have never been questioned on it by the regulators?

I'm finding a ton of these types of things that I have done in the past that hasn't been done here. Why are they not being written up on these items?

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General Discussion
#2228686 - 01/09/20 09:27 PM Re: Vendor Management/OCC OliviaG2014
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,371
Galveston, TX
Under 12 USC 1867(c)(2), national banks are required to notify the OCC of the existence of a servicing relationship. FSAs are subject to similar requirements set forth in 12 USC 1464(d)(7)(D)(ii) and 12 USC 1867(c)(2). The OCC implements this notification requirement by requiring banks to maintain a current inventory of all third-party relationships and make it available to examiners upon request.

As to your other question, it is because it hasn't been looked it.

Yet.
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#2228690 - 01/09/20 09:35 PM Re: Vendor Management/OCC OliviaG2014
OliviaG2014 Offline
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Joined: Jan 2020
Posts: 21
I completely agree with that statement. I keep telling them that when they say the famous last words "But we never got in trouble for that before."

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