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Co-developing products with a fintech

03/31/2024

What if our bank is considering co-developing a digital product with a fintech that we have worked with in the past? Is this relationship managed in the same way as other fintechs?

Due diligence cannot rely on vendor reputation

03/17/2024

Do we really need to conduct due diligence on all of our 3rd party vendors, including fintechs? I can understand the ones that appear to be riskier, but there are some that are very well-known in the industry and are very well respected. Wouldn’t the regulators just see the same thing in our file as they did the last bank they just left?

When vendors are not cooperative

03/17/2024

How do you deal with a vendor point of contact who is not providing you with the documentation that you are requesting?

Records access for compliance monitoring

03/10/2024

When we do engage new vendor, especially fintechs for new digital banking products (like BNPL or Buy Now Pay Later), what type of access to records should we expect to have to be able to monitor for compliance?

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Account service agreement for MSB accounts

03/23/2025

I need suggestions for preparing an account service agreement for MSB accounts. We have a questionnaire attached to our applications to confirm transactions, etc., but lack a true service agreement beyond our standard commercial account agreement.

Extended OFAC records retention period

03/16/2025

My question is about the new OFAC retention rules effective March 12, 2025. What records are covered? Will OFAC checks at new account opening need to be kept 10 years now or is the new rule just for hits and blocked property?

Telephones in Vaults

03/16/2025

Is it still a good practice, or industry standard, to have a telephone hidden in the cash vault? We recently revamped our phone system, and in the process, most of the vault phones in our 8 branches were disconnected. Nobody checked with the Security Officer, they just determined that the phone lines in question didn’t have any history of being used, so they got disconnected. I recently did a Security Officer walk through of all the branches and discovered the vault phones were not working. My recommendation was to hook them back up and I’m getting push back because of the cost.

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