Put the required provisions in every contract

Vendor Management policy, §5.3, §7, §14

Every contract carries the standard provisions; critical service provider contracts add the sponsor bank’s step-in, direct reporting, audit and examination, material-change, flow-down, retention, and transition rights; any contract with customer data access adds data ownership, permitted use, safeguards, breach notification, and return-or-destroy terms.

Event-driven

Each new contract and each renewal or amendment

Check the contract against the provision list for its tier and data access, negotiate the gaps with outside counsel for Tier 1 and significant Tier 2 contracts, and file the executed agreement with a provision checklist.

• Executed contract with provision checklist

  Each required provision marked present with its clause reference

Compliance Officer

Counsel negotiates the contract; Leela can check a draft against the provision list and file the checklist.

Tell Leela about your company to see whether this applies.