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FRM Part II · FRM Exam Part II · Case Study: Third-party Risk Management

A regional bank moves its customer-complaint handling to an external call-centre provider. Under widely accepted third-party risk principles, which statement best describes the bank's accountability for complaint-handling outcomes after the move?

The bank keeps ultimate accountability. Outsourcing moves the performance of the activity to the provider but not the responsibility for it, so the board and senior management remain answerable to customers and supervisors, regardless of contractual liability allocations between the parties.

  1. AAccountability transfers to the provider once a signed contract is in place
  2. BAccountability is shared equally between the bank and the provider's regulator
  3. CThe bank retains ultimate accountability for the activity and its compliance outcomesCorrect
  4. DAccountability rests with the provider for operational failures but with the bank for strategic failures only

Explanation

Outsourcing transfers the performance of an activity, not responsibility for it. The board and senior management of the bank remain accountable to customers and supervisors. The first option is wrong because a contract can allocate liability between the parties but cannot remove regulatory accountability.

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