Third-Party Relationships and Agreements the utilization of 3rd events by no means diminishes the obligation associated with board of directors and administration to ensure the third-party task is conducted in a safe and sound way plus in compliance with policies and relevant laws and regulations. Appropriate corrective actions, including enforcement actions, might be pursued for inadequacies linked to a third-party relationship that pose concerns about either security and soundness or perhaps the adequacy of security afforded to customers.
Examiners should gauge the institution’s danger management system for third-party payday financing relationships. An evaluation of third-party relationships ought to include an evaluation associated with the bank’s risk evaluation and strategic preparation, along with the bank’s homework procedure for choosing a qualified and qualified 3rd party provider. (make reference to the Subprime Lending Examination Procedures for extra information on strategic preparation and homework.)