copyright © 2014 lender performance group, llc. all rights reserved. managing risks associated with...
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Copyright © 2014 Lender Performance Group, LLC. All rights reserved.
Managing risks associated with third-party relationships,
in other words Vendor Management
Presenters: Joel Rosenberg, CFA Chris Nelms, CISM, CRVPM
loan pricing & profitability management solution
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Vendor Management
• OCC guidance issued late 2013• Appendix J by FFIEC• Vendor Management, referred to as third-
party service provider (TSP)• Comprehensive risk management and
oversight
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Use of third party vendors (TSP) increasingly complex
• Outsourcing entire departments• Outsourcing business lines• More Traditional Activities• Issues:• Customer Contact• Domestic and/or foreign subcontractors
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5 steps in Risk management Life Cycle
• Developing a plan• Review of TSP pre-contract• Contract - expectations and responsibilities • Monitoring• Termination• Parallels to the lending process, new loan
product introduction
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Parallels to what an Institution does in introducing a new loan product
• Planning • Due Diligence- Underwrite the 5 C’s http://
lenderperformance.com/topics/vendor-selection/
• Contract Negotiation-Loan Documentation • On Going Monitoring- Credit Analysis, ROE• Termination- Loan Paid or other options
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Planning• TSP Management• Strategic purposes• Compliance aspects• Complexity• Potential information security implications• Inherent risks of using vendors • Board presentation and approval of critical
activities
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New Loan Program Parallel- Planning
• Market and need• Customer interaction• Compliance aspects • Inherent risks -Credit, IRR, Regulatory • Administration
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Due Diligence- TSP
• Vendor’s business strategy• Licenses, fidelity bond coverage • Financial condition• Resources and experience• TSP fee structure and incentives• Information security programs • Reliance on subcontractors
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Due Diligence- Loan Program
• Underwriting Criteria• Type of borrower • Financial condition• Experience• 5 C’s
• Underwrite in-house or TSP
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Contract Negotiation- TSP• Nature of Arrangement• Performance Measures or Benchmarks• The Right to Audit (SSAE 16, SOC1, SOC 2,
SOC 3 reports)• Cost and Compensation• Business Resumption Plans• Dispute Resolution• Default
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Contract Negotiation- Loan Program
• Provisions and terms• Pricing methodology (ROE targets)• Default• Performance Measures• Report requirement
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Ongoing Monitoring - TSP
• Bank’s risk operation• Critical activity• Regular on site visits• Vendor controls, service-level agreements • Key personnel and retaining essential
knowledge • Subcontractors –reliance and performance
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Ongoing Monitoring – Loan Program
• Periodic client reports• Spreading the financials• Collateral monitoring• Regular on site visits• Client key personnel changes
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Termination- TSP
• The bank may terminate third-party relationships
1. expiration or satisfaction of the contract2. bring in alternate TSP3. in-house4. breach of contract
• In-house option, planned or not:1. capabilities, resources, and the time frame 2. risks - data retention and destruction3. handling of joint intellectual property 4. reputation risks
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Termination- Loan Program
• Ending the Loan Program• Foreclosure experience• All existing loans pay off• Sale or transfer
• Reputation Risk• Personnel Considerations
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Oversight and Accountability
• Board of Directors• Effective process is in place • Approve the bank’s risk-based policies • Review due diligence• Approve contracts that are critical activities
• Senior Bank Management• Implement the bank’s TSP plan or Loan Program
operation• Due diligence• Review and approve contracts/loan documents • Ensure periodic independent reviews• Oversee ERM
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Oversight and Accountability
• Bank Employees• Conduct due diligence• Perform ongoing monitoring • Escalate significant issues• Tested controls in place • Maintain appropriate documentation • Respond to material weaknesses
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Independent Reviews
• Ensure that periodic independent reviews are conducted• Reviews should assess :• ensuring third-party relationships and loan
program align with the bank’s business strategy• risks • material breaches and service disruptions• identifying and managing concentration risks • ensuring that conflicts of interest do not exist
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Vendor Management (TSP)• Vendor Management is your first
line of defense against security breaches.
• Stop the checkboxes! • Create a program
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Vendor Management
• Obtain Executive Sponsorship• Create a vendor management Committee. • Create a centralize vendor management
program. • Gain buy-in!
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Vendor Management
• Create a vendor inventory • Categorize all vendors• Remove the silo
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Questions
Presenter: Joel Rosenberg and Chris Nelms
Contact: [email protected] or [email protected]
Phone: (980) 297-7100