FRM Part II · FRM Exam Part II · Case Study: Third-party Risk Management
A bank's third-party risk policy requires an exit strategy for critical outsourced services. A regulator reviewing the bank finds that the sole provider of its payment processing has no tested transition plan and the contract has no termination-assistance clause. Which conclusion is most consistent with supervisory expectations?
This is a deficiency. Supervisors expect banks to be able to exit or transition critical outsourced services without unacceptable disruption, supported by termination-assistance clauses and tested exit plans. A provider's rating or continuity plan does not replace the bank's own exit capability, and geography is not the deciding factor.
- AAcceptable, as long as the provider has a strong financial rating
- BAcceptable, because the provider's own business continuity plan covers the bank
- CA deficiency, because the bank must have contractual and operational ability to exit or bring the service in-house without unacceptable disruptionCorrect
- DA deficiency only if the provider is located in a different country
Explanation
Supervisors expect banks to plan for provider failure or termination, including contractual termination assistance and tested exit plans for critical services. A provider's rating or its own continuity plan does not give the bank the ability to transition. Location matters for other risks but is not the trigger for this deficiency.
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