Kutak Rock attorney Bryan Handlos authored the article “An Ounce of Prevention: Business Continuity and Incident Response in Technology Service Provider Contracts” for the May/June 2019 issue of Nebraska Banker. The article is featured in the Counselor’s Corner section of the publication, which focuses on providing guidance on relevant legal issues.

In this article, Mr. Handlos discusses the FDIC’s recently issued Financial Institution Letter 19-2019 (FIL-19-2019) which focuses on vendor management tasks, specifically business continuity and incident response preparedness. As stated in the article, “the occurrence of a vendor business continuity event or a vendor information security breach has the capacity, like a building fire, to cause significant harm.”

Although FIL-19-2019 provides little detailed guidance on steps a bank should use to avoid examiner criticism related to gaps in new and existing vendor contracts, Handlos’ article proposes some practical action steps to avoid or minimize bank examiner criticisms called out in the letter.

Bryan Handlos is a member of the firm’s banking practice group and concentrates his practice on bank regulatory and consumer financial services matters.

An Ounce of Prevention: Business Continuity and Incident Response in Technology Service Provider Contracts