2016 – the year of third party risk and cybersecurity. As 2016 winds down, we should look back and think about what we’ve seen this year. There have been many extraordinary events in the world of vendor management. Let's take a look at some examples.
Here are some highlights...
- We’ve seen major enforcement actions related to third party activities, perhaps none bigger than the $35 million penalty against First National Bank of Omaha for UDAAP violations tied to the use of add on products and fees.
- We’ve seen major breaches – headlined by the SWIFT attacks over the summer.
- We’ve seen updated FFIEC guidance on mobile banking.
- We’ve seen a real national mandate on cybersecurity efforts, including the creation of an executive administration level task force.
- We’ve seen the release of voluminous new regulations from the 900-page mortgage ruleto the 1,700-page prepaid regulation.
- We’ve seen FinCEN’s final rule on enhanced Customer Due Diligence and Beneficial
- We’ve seen the announcement of a proposed rule on heightened cybersecurity
Regardless of your views on political conditions in the US, this has been a year of amazing challenges, new controversies and old standards put to the test.
As we move into 2017, I hope we can do so in a spirit of optimism, renewed vision and a determination to make significant progress in vendor management and financial services compliance.
Make progress in 2017 within your financial institution's vendor management program...utilize our infographics, eBooks and guides in our Resources Library to help!