The basis for any response to Part 370 will be a thorough analysis of customer, account, and deposit data across the organization. This can be a massive undertaking at an organization the size of those targeted by Part 370. We have led dozens of data analysis and remediation efforts across industries, including:
- System identification: Looking across the organization’s various functions, business units, and possibly geographies to identify all sources of relevant data
- Data analysis: Cataloging the various places that relevant data exists and determining the quality of existing data and gaps with respect to Part 370 requirements
- Data remediation: Creating a plan for addressing data gaps and quality issues, as well as defining survivorship rules in cases of multiple sources for similar data
- Data origination: Documenting and improving the processes in place for new data generation, such as account opening and integrations with third parties
- Data security: Mapping the organization’s data security protocols and assessing its adequacy to support the storing and possible transmission of customer data relating to Part 370
With an understanding of the company’s data in place and a plan for addressing any shortcomings, the company will have a solid foundation for crafting a response to Part 370.
—
If you are interested in learning more about FDIC Part 370 and how we can help you comply with the rule, please download our comprehensive guide or complete the contact form at the bottom of this page.
