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The TSP: An Important Consideration

By Jolley | Hadaway | Thursday, December 22, 2016 - Leave a Comment

Something to look at when choosing your next service provider. . .

A short Jolley | Hadaway article

FFIEC Logo - blue hollow 5 part star with FFIEC in blue font below star

In our due diligence packet prospects and clients eventful tax will discover that we are proud to be part of a program that is called the FFIEC’s Technology Service Providers (TSP) examination program.

In 2009 infotex volunteered to be in a pilot program which evolved into the FFIEC’s TSP examination program.  While we are not able to discuss the details of what happens when we are examined by the FFIEC, we do believe that our Clients, especially those who are banks or credit unions, need to understand the value of hiring vendors who are in the TSP examination program.  Suffice it to say the program requires us to maintain a robust audit program both internal and external that is reviewed along with financial statements, contracts, policies and procedures when we are examined.

We are not allowed to say anything about what happens in a specific examination but we are allowed to say which cycle we are on and when the examiners point that out they always say this will help your bankers and prospects understand your level of safety.  We are proud to say that while the first two exams were a year apart, but then we were switched to a two-year cycle starting in 2010/12.  In 2016, we were switched to a three-year cycle.  We do occasionally have findings that our financial institution Clients can discover in the TSP ROE.  We cannot discuss those findings unless our Client contacts us about them.

This program has substantially improved our own business, and it make sure that clients of the FDIC, the Federal Reserve, the OCC and the NCUA are working with vendors that have a certain level of safety and soundness.  We encourage our Clients to add to the vendor due diligence process the step of contacting your federal regulator to ask for the TSPROE on every one of your vendors who have access to your network or that host PII on your behalf.

Original article by Dan Hadaway and Matt Jolley.

Jolley | Hadaway shorts are quick takes on subjects that we think you should know about.



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