Does anyone know if the agencies are okay with the changes to the FISI program?

Please explain what changes to the FISI program. Thanks

There may be some issues to address. Look at the Interagency Response.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

I just visited with our inhouse person that works with FISI, and she couldn't tell me what changes have been made to FISI. I would appreciate information on changes also.

Thanks

The change I was referencing was that account numbers would no longer go to FISI (but for some reason encrypted numbers would still go to FISI). Account numbers would go to a 3rd party for "servicing" enrollees, but it seems that those numbers would go to this new third party on all those being marketed to. I was curious whether this new structure had been reviewed and/or blessed by the Agencies.

More Info: FISI distributed to some financial institutions its outside Counsel opinion on the above after the agencies issued an opinion to FISI. In general, the counsel gave blessing to a "new" scenario, i.e., don't send FISI unencrypted numbers, but when you have customer consent for the product, send unencrypted numbers to "your service provider" which happens to be a FISI affiliate. Anyone know if (1) FISI plans to get another regulatory opinion letter on this new way, and (2) How prudent is it to follow without either your own counsel opinion or the regulatory approval.?

We have been able to obtain a copy of FISI's legal opinion and have had a discussion with their counsel regarding the account number sharing issue. (1) It is my understanding that FISI will not seek approval from the regulatory agencies for its "revised" changes. As I understand it, FISI did not believe that the agencies were going to speak on this issue anytime soon, and that we are pretty much left to play guessing games. (2) I would strongly encourage you to receive blessing from your own counsel regarding this procedure. I have not given our bank the green light to share account numbers with FISI. I am not confident that the procedure outlined by FISI is at all compliant. Additionally, FISI will not be sitting across the table from the regulators when an institution is questioned on its practices. You will. So I would think financial institutions would want to be fairly comfortable with FISI's procedure in order to attempt to explain away any potential regulatory criticism.