Is Your Bank Reviewing Its Technology Contracts?
In an article in the ABA Banking Journal, Brad Rustin and Samer Roshdy of Nelson Mullins Riley & Scarborough discuss the FDIC’s financial institutions letter FIL-19-2019, highlighting contractual deficiencies in banks’ contracts with technology service providers.
“The FDIC letter reaffirms the long-standing regulatory notion that a financial institution cannot discharge its responsibilities, which includes managing its business continuity and incident response processes, by outsourcing activities to third-party service providers,” they explain.
The authors also add that the letter serves as a reminder to the industry that federal banking regulators will continue to scrutinize relationships with technology service providers.