Records access for compliance monitoring

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Question:

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?

Answer:

Your vendor should be open to you and your expectation of access to ensure that compliance, especially for consumer protection areas such as fair lending, are made available to you. Just because the vendor is “providing” the services to your customers does not alleviate you from the ultimate compliance responsibility so make sure that you clearly understand what actual functions, services, and decisions are being “owned” by the bank versus the vendor. The ultimate liability for all compliance will always stay with the bank.

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Learn more about Maureen Carollo’s Vendor Due Diligence & FinTechs webinar.