Leela
Change Management
CG-05

Obtain the sponsor bank’s written approval for critical service provider changes

Policy reference

Change Management policy, §3.1, §3.2, §5

Interagency Guidance on Third-Party Relationships: Risk Management, 88 FR 37920 (June 9, 2023), due diligence and third-party selection; contract negotiation
Requirement

The Company does not sign an agreement with a critical service provider without the sponsor bank’s prior written approval, and notifies the bank in writing at least 30 days before signing, describing the services, scope, pricing, term, and the key terms on data security, confidentiality, compliance, and termination. A material change to an existing critical service provider agreement requires the bank’s prior written approval, and terminating one requires 60 days’ written notice. Every critical service provider agreement carries the bank’s step-in and direct reporting rights.

Trigger

Event-driven

Each new, changed, or terminated critical service provider; 30 days before signing, 60 days before terminating

Action

Identify the change as a critical service provider change at triage, send the bank the notice with the required description, obtain and file the written approval before signing or changing scope, and give the 60-day notice before any termination.

Evidence
  • Critical service provider notice

    Services, scope, pricing, term, key terms, date sent, days before signing

  • Sponsor bank written approval

    Approval letter or email, date, conditions

  • Termination notice

    Provider, planned end date, date notice sent

Owner

Compliance Officer

Leela can
Human required

A person must do the work; Leela can track it and file the evidence.

Leela can keep the 30-day and 60-day clocks and hold the file open until the approval lands, but the bank’s approval is a decision only the bank can make.

Applies

Tell Leela about your company to see whether this applies.

Status
Setup needed

Tell Leela how you handle it today, or hand it over: see what’s next.

What’s next?