May 16, 2013  Banks have been using third parties to achieve
their strategic goals for years, but new legislation and
stricter enforcement of existing regulations are highlighting
the need for management to ensure that the selection of and
contracting with third party providers is conducted in a manner
that guarantees compliance with applicable laws and mitigates
supply chain risk.  Legislators and regulators acknowledge that
judicious use of third party relationships offer banks
legitimate opportunities to increase or ensure profitability,
enhance their offerings and improve efficiency. It is equally
critical to recognize, however, that use of third parties does
not absolve the bank of its duties and responsibilities relative
to the performance of those third parties or the bank’s
requirements to be compliant with relevant regulations. In fact,
there is a fundamental expectation that any bank using a third
party will properly oversee and manage that third party
relationship to the same extent that it would i