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Vendor Due Diligence from a Regulatory and Common Sense Perspective The Ways of Credit Unions “Pretty People” Numbers Incentives – Why and Long Term Effects Vendor Due Diligence I A. NCUA and FFIEC Guidelines or Requirements (See NCUA Letter Nos: 00-FCU-11; 07-FCU-13; 01-CU-20; and 08- FCU-09 as applicable) **POLICIES AND PROCEDURES ** Step One: Needs Assessment and Basic Due Diligence Queries (who, what, where ….) Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 24
Vendor Due Diligence II Security Assessment of a Vendor If applicable, has the Vendor provided their SAS-70; ISO 17799 or other compliant Independent assessment of technology, data and information security systems and compliance to the Credit Union? Is there any basis for concern based on such report(s)? Vendor Due Diligence IV D. The Big Deal About the Contract: Is Your Credit Union in Love? The “Pre-Nup” Before – During --After! Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 25
Page 1 and 2: Compliance Update - I REGULATORY AN
Page 3 and 4: Introductory Notes: Basic Obligatio
Page 5 and 6: performed by boards of directors. T
Page 7 and 8: What if an applicant “volunteers
Page 9 and 10: Please answer the following questio
Page 11 and 12: MULTIPLE ISSUES AND RESOURCES - SOM
Page 13 and 14: • Review of the negative shares r
Page 15 and 16: illustrates how certain provisions
Page 17 and 18: SAMPLE CREDIT UNION BUSINESS PLAN M
Page 19 and 20: EMPLOYMENT AGREEMENT Revise to addr
Page 21 and 22: 13. Evaluate the job performance of
Page 23: 2. By Employer For No Cause. Employ
Page 27 and 28: Vendor Due Diligence VII TERM AND T
Page 29 and 30: Vendor Due Diligence XII Backgroun
Page 31 and 32: Monitoring the Vendor At a minimum,
Page 33 and 34: NOTE: The BSA also contains a “wh
Page 35 and 36: (5) Confidentiality of reports. SAR
Page 37 and 38: PRIVACY - INFORMATION SECURITY Priv
Page 39 and 40: Disposal of Consumer Reports and Ot
Page 41 and 42: Compliance Update - II REGULATORY A
Page 43 and 44: Introductory Notes: Knowing if you
Page 45 and 46: I. POLICY AND GUIDELINES Portions O
Page 47 and 48: any CUSO. [Gifts may not be accepte
Page 49 and 50: Conference and Seminar Costs Fees f
Page 51 and 52: We have stated that there must be a
Page 53 and 54: IV. POLICY REGARDING CONFLICTS OF I
Page 55 and 56: public, even though, such relatives
Page 57 and 58: and other relatives who live in the
Page 59 and 60: protection, and the reimbursement o
Page 61 and 62: Legal / Compliance Consultation Not
Page 63 and 64: MERGER AND CONSOLIDATIONS ISSUES NO
Page 65 and 66: information of which unauthorized d
Page 67 and 68: A Review of ‘Red Flags’ and wha
Page 69 and 70: Business Depositors: Understanding
Page 71 and 72: WHAT POLICIES, PROCEDURES AND RISK
Page 73 and 74: 16. Conflict of Interest/Code of Et
Page 75 and 76:
Union Assessment 33. Identity Theft
Page 77 and 78:
Procedures 60. Training Policy See
Page 79 and 80:
Also - consider the other changes c
Page 81 and 82:
policies, procedures and documents
Page 83 and 84:
Underwriting Advertising In July 20
Page 85 and 86:
135-2009 Community Notice // OE/CE
Page 87 and 88:
Credit Union’s lien right are not
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