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Welcome

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Introduction

This course will provide you with an understanding of Third Party Credit Risk Fundamentals.

After completing this course, you will be able to:

  • Explain the role of the Third Party Credit Risk Group (TPCRG)
  • Describe how TPCRG interacts with Citi’s Third Party Management program
  • Define roles and responsibilities of Stakeholders in the Third Party Management process and Lines of Defense Construct
  • Explain the review and challenge that TPCRG performs as part of the Third Party Credit Risk (TPCR) and Third Party Performance Risk (TPPR) approval processes.

This course is divided into six topics and an end-of-course assessment. After completing the training content, you must score 80% or higher in the assessment to receive credit for this course.

The Resources button includes access to a Glossary of Acronyms used in this course.

Welcome

Are you already familiar with Third Party Credit Risk Fundamentals?

If so, this training includes an opportunity for you to demonstrate your knowledge by completing a test out. Successful completion of the test out will allow you to take an accelerated path through the training by skipping the training content to receive credit for the course.

To continue to the test out, select the Take the Test Out button.

If you prefer to skip the test out and go straight to the content, select the Start the Course button.

Third Party Credit Risk Group

Third Party Credit Risk Group Introduction

The TPCRG is a centralized Global Independent Risk function that covers Citi-wide External Third Party activities. TPCRG supports Third Party Management (TPM) with initial due diligence and periodic reviews of External Third Party Engagements, providing oversight of Financial Risk Assessments and approvals of Third Party Credit Risk.

While there are additional TPCRG oversight functions in US Personal Banking and Wealth products/processes, this course will focus on TPCRG’s Citi-wide responsibilities:

  • Third Party Performance Risk (TPPR) - review and challenge the financial analysis performed by the First Line of Defense and issue objection or no objection to the engagement of External Third Parties
  • Third Party Credit Risk (TPCR) - provide approval of Third Party Credit Risk

Review the slide below to learn more about Third Party Performance Risk. Then, select the arrow on the right to proceed to the next slide containing an example of TPCR.

 

Third Party Performance Risk (TPPR)

TPPR refers to an External Third Party’s financial capacity to perform its obligations under the contract(s) with Citi.

TPCRG (in its role as Second Line of Defense) reviews/challenges/provides objection or no objection to the financial analysis and the proposed Financial Capacity to Perform (FCP) rating prepared by the Third Party Management Financial Risk Assessment (TPM FRA) team (in its role as First Line of Defense).

 

Example of TPCR

TPCR exposure arises when there’s an agreement for an External Third Party to hold, collect, prepay, or settle Citi Funds, where some form of a guarantee or commitment is given to Citi by an External Third Party or a liability to Citi exists as a result of an External Third Party relationship.

Example: Collection Agency – Citi’s money is in the Third Party’s possession upon collection.

The failure of a Third Party to perform under a TPCR agreement could result in a financial loss and negatively impact Citi’s earnings and capital.

It is the responsibility of each business or global function to identify TPCR in their own organization. The Third Party-Risk Assessment Process (TP-RAP) assists in this identification.

TPCRG (in its role as Second Line of Defense) reviews/challenges/approves the financial analysis and the TPCR Management Action Trigger (MAT) calculated by the Commercial Lending Management Third Party Credit Risk (CLM TPCR) team (in its role as First Line of Defense).


 
 

Citigroup Third Party Landscape

Citi’s Third Party relationships span North America and all International regions.

To proceed, select each card to learn more about Citi’s Third Party relationships.

Global external Third Party relationships

Global external Third Party relationships

As of December 2020, Citi had approximately 12,000 external Third Party relationships with over 7,500 Third Party parent companies.

Citigroup’s Spend on Third Party relationships

Citigroup’s Spend on Third Party relationships

Citigroup spent $18.49B on External Third Parties in 2020. $8.8B of this spend was with external third parties within TPCRG’s scope (2020).

Approved by TPCRG

Approved by TPCRG

TPCRG approved 483 External Third Parties with TPCR exposure (as of 12/31/20). The approved MAT exposure was $9.5B.

More About Third Party Credit Risk

TPCR arises when there is an agreement with an External Third Party to either hold, settle, prepay, or collect Citi Funds, where some form of a guarantee or commitment is given to Citi by an External Third Party or a liability to Citi exists as a result of an External Third Party relationship. The failure of an External Third Party to perform could result in financial loss negatively impacting Citi’s earnings and capital.

To proceed, select each image to learn more about TPCR.

Agreements
 

Agreements with External Third Parties to either hold, settle, pre-pay or collect Citi’s funds:

  • Collection agencies and collection law firms
  • Cash vault services
  • Loan servicing companies
  • Settlement vendors
  • Prepaid maintenance contracts
Guarantee or Liability
 

Some form of a guarantee given to Citi by an External Third Party or a liability to Citi exists as a result of an agreement:

  • Club membership providers / Warranty purchases
  • Revenue or minimum return guarantees
  • Credit insurance or mortgage insurance

Third Party Credit Risk (TPCR) Categories - Prepayment


Most TPCR falls into one of several categories. Let’s begin with Prepayment.

Prepayment is Citi’s advanced payment for a service that hasn’t been performed, with the prepayment period of greater than six months, and with the amount of at least US$1MM.

Prepayment could come from any kind of service, such as:

  • Software licensing
  • System maintenance
  • Employee healthcare services, etc.

For example, Citi pays a computer services company US$9MM in advance for the purchase of software including its maintenance and software upgrades throughout the life of the contract.

TPCR Categories: Loan Servicing

Loan servicing is another opportunity for TPCR.

Review the slide below to learn more about Loan Servicing Companies. Then, select the arrow on the right to proceed to the next slide containing an example of Loan Servicing.

 

What Do Loan Servicing Companies Do?

Loan servicing companies provide customer service, collection, payment processing and support functions on behalf of the loan originator.

 

Example of Loan Servicing

For example, Citi Singapore owns a mortgage portfolio but outsourced its loan servicing to an External Third Party to collect mortgage payments on behalf of Citi, thus, meeting the definition of TPCR.

 
 

TPCR Categories: In-store Payment

In-store payment providers include supermarkets, small retailers, post offices, etc. They may accept various bills/loans/credit card payments on behalf of Citi.

For example, Citi Panama collaborates with the local convenience store chain so that Citi’s credit card customers can make Citi card payments in the convenience store.

TPCR Categories: Indemnification

In External Third Party relationships, indemnification is typically contingent upon a future event that may or may not occur.

Review the slide below to learn more about Indemnification Risk. Then, select the arrow on the right to proceed to the next slide containing an example of Indemnification.

 

Indemnification Risk

This exposure arises from a receivable, unrelated to loans (termination penalty, minimum return, loss reimbursement, bonus claw back), owed to Citi as a result of a specific event.

 

Example of Indemnification

For example, Citi Brazil enters into a card partnership contract with an airline. If the airline terminates the contract earlier than agreed, the airline must pay Citi an early termination fee of US$7MM.

 
 

TPCR Categories: Vault/Cash Services

The final TPCR category is Armored Car/Automated Teller Machine (ATM) service.

To proceed, select each button to learn what armored car/ATM service providers are responsible for.

 

Delivery

Physical cash delivery to and from Citi’s branches, Citi’s customers, and National Banks.

Cash processing, storage, and replenishment

Cash processing, ATMs replenishments, and storage/counting/packaging money in vaults for both Citi branches and corporate clients.

Example of Armored Car/ATM Service

An armored car service picks up/delivers Citi cash to/from ATMs in British Columbia. The provider consolidates the cash and holds it overnight in their vault before transmitting it to Citi to complete the service.

Check Your Understanding

Which category of Third Party Credit Risk is contingent upon a future event that may or may not occur?

Select the best response and then select Submit.

Please use the Space key only when selecting a radio option with the keyboard. The Enter key is not fully supported. If the Enter key has been used to select a radio option, please use the Escape key. Then you will be able to use the Space key again to select a radio option.

Coming Next

You’ve seen an overview of the main functions of the TPCRG and how TPCR is created. Next, we’ll explore the broader topic of Third Party Management.

Third Party Management Program

Importance of TPM


Citi uses a large number of External Third Parties to support business operations, client-facing processes and to deliver innovative products and services. Failure to assess and manage the level of risk and complexity of these External Third Party relationships may lead to:

  • Operational disruptions
  • Fraud
  • Cyberattacks
  • Customer impact
  • Reputational damage
  • Financial losses
  • Regulatory fines and enforcement actions

TPM plays an important role in managing and mitigating risks associated with Citi’s use of External Third Parties, enabling enterprise-wide businesses and functions to achieve Citi’s mission of being the best for its clients.

The TPM process is a risk-based approach for managing External Third Party relationships, with dedicated oversight of high-risk relationships. The TP-RAP, discussed later in this course, provides the structure for identifying the inherent risks in a relationship and the required level of due diligence/ongoing monitoring based on the identified risks.

Citi has 22,500 external contracts in eSourcing. There are 7,500 External Parent Third Parties in the Citi-Approved Supplier Program (CASP), and 12,000 External Third Party relationships in CASP.

Managing External Third Parties

The engagement and management of External Third Parties is governed by Third Party Management Policy (TPM Policy). Business Activity Owners (BAOs) are required to ensure the financial condition of an External Third Party is reviewed during the initial due diligence and ongoing periodic monitoring process. The financial condition review evaluates the likelihood that the External Third Party will remain financially sound and able to perform under the contract with Citi.

The Third Party Credit and Performance Risk Policy and the Third Party Credit and Performance Risk Procedure outline the requirements for performing this evaluation as part of the overall framework of third party management.

In addition to providing a review/challenge of an External Third Party’s financial capacity to perform rating, TPCRG is an active participant in negotiations of significant External Third Party agreements assuring:

  • Performance risks are identified, monitored, and mitigated
  • Credit exposures are quantified, approved, monitored, and captured in the Risk Systems

Third Party Risk Assessment Process

The Third Party Risk Assessment Process (TP-RAP) provides a structured and objective methodology for:

  • Identifying the inherent risks associated with an External Third Party relationship
  • Determining the required level of pre-contract due diligence and post-contract ongoing monitoring based on the identified risks

One of the risks identified by the TP-RAP is TPCR. Let’s look at how TPCR is identified in the TP-RAP.

How is TPCR identified in the TP-RAP?

Specific answers in the TP-RAP indicate the existence of TPCR.

To proceed, select each button to learn more about these specific answers.

 

“Yes” answer to TP-RAP Question 9

For new relationships, will these products/services require:

  • The Third Party to hold Citi funds of ≥ $1,000,000 overnight or longer period (e.g., through collections, settlement, Cash-In-Transit); or
  • The Third Party to give Citi a guarantee (e.g., credit guarantee, return guarantee); or
  • Citi to have a contractual obligation to make prepayments ≥ $1,000,000 and for periods greater than 6 months?

“Yes” answer to Question 7 of the Material Change Identification and Attestation (MCIA) form

For extending, renewing, or amending an existing relationship, will the Contract Renewal/Amendment result in any addition of or increase in the TPCR exposure?

Check Your Understanding 1 of 2

Which of these statements is true about the TPM process?

Select the best response and then select Submit.

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Check Your Understanding 2 of 2

TPCR exists in which of the following circumstances?

Select the best response and then select Submit.

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Coming Next

We’ve explored the Third Party Management program. In the next topic, we’ll discuss Stakeholder roles and responsibilities within the Third Party Management Process and Lines of Defense construct.

Stakeholder Roles and Responsibilities

Risk Accountable

Any role that performs a risk-generating activity, regardless of which line it resides in and therefore requires risk/control oversight of Independent Risk management, is designated as Risk Accountable.

To proceed, select each tab to learn about three risk accountable roles.

Business Activity Owner (BAO)
BAO Support
Third Party Officer (TPO)

Business Activity Owner (BAO)

The BAO is ultimately accountable for the risk of the Citi activity or business process even if an external third party performs the activity on its behalf.

This includes, but is not limited to, ensuring that the activity is performed in a safe and sound manner and in compliance with applicable laws, regulations and in a manner consistent with Citi policies and standards.

BAO responsibilities include:

  • Monitor TPCR exposure and ensure it remains within the approved Management Action Trigger (MAT).
  • Support escalations for privately held External Third Parties failing to provide complete financial statements. Review financial analysis results via OneTPU and address documented concerns.
  • Consider financial capacity to perform rating in the External Third Party selection process.
  • Receive Adverse Results control for Financial Risk Assessment of External Third Parties with Poor or Marginal financial capacity to perform ratings and complete the control by following guidance provided in Assess Financial Risk L3 Procedure.

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BAO Support

BAO Support is a role within the Business, or the Resource Management Organization’s Third Party Utility, assigned to BAOs to assist them with the completion of their third party risk management activities.

BAO Support is responsible for performing certain activities within the Third Party Relationship Life-Cycle on behalf of the BAO.

This is solely a support role and does not reduce the ultimate accountability of the BAO.

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Third Party Officer (TPO)

Third Party Officers (TPOs) report into the Businesses/Global Functions and are responsible for performing certain activities within the Third Party Relationship Life-Cycle.

TPOs work with the Business, Operations and Technology (O&T) teams, as well as other Citi functions to:

  • Maximize the Businesses’ engagement with the External Third Party
  • Identify, manage and mitigate risk throughout the Third Party Relationship Life-Cycle

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First Line of Defense

Each of Citi’s businesses own the risks inherent in or arising from its business. These units are responsible for identifying, assessing, and controlling those risks so that they are within risk appetite. They may also conduct control and support activities.

It is the responsibility of each Citi business or global function to identify TPCR in its own organization as the First Line of Defense.

  • The Business must engage TPCRG to ensure credit approval of TPCR is obtained.
  • The Country Risk Officer or Business Chief Credit officer should ensure appropriate staff are aware of necessary requirements and policies for assessing and approving TPCR exposures.

To proceed, select each tab to learn more about the First Line of Defense in relation to Third Party Credit Risk (TPCR) and Third Party Performance Risk (TPPR).

Third Party Credit Risk (TPCR)
Third Party Performance Risk (TPPR)

Third Party Credit Risk (TPCR)

The First Line of Defense for TPCR is the CLM TPCR team. CLM TPCR is responsible for:

  • Completing the financial analysis via TPCR Credit Approval Memorandum (TPCR CAM) on new and existing in scope External Third Parties
  • Quantifying and proposing the TPCR MAT exposure for the next 12 months
  • Requesting approval of the proposed TPCR MAT

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Third Party Performance Risk (TPPR)

The First Line of Defense for TPPR is the Third Party Management Financial Risk Assessment (TPM FRA) team. TPM FRA is responsible for:

  • Completing the financial analysis via Financial Risks Assessment (FRA) on new and existing in scope External Third Parties
  • Proposing Financial Capacity to Perform under the contract rating as (1) Strong; (2) Adequate; (3) Marginal; or (4) Poor
  • Reviewing/​challenging/​confirming the Adverse Results Financial Risk Assessment control completed by the BAO for third parties with a Financial Capacity to Perform rating of Marginal or Poor

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Second Line of Defense

The Second Line of Defense is responsible for overseeing the risk-taking activities of the First Line(s) of Defense and challenging their execution of risk management responsibilities. The Second Line of Defense must independently identify, measure, monitor and control aggregate risks using consistent definitions and approved methodologies.

The Second Line of Defense for TPCR and TPPR is TPCRG, a centralized Global Independent Risk function. TPCRG performs:

  • The review/​challenge/​objection or no objection to the Financial Risk Analysis performed by TPM FRA team (First Line of Defense)
  • Risk oversight and approval of TPCR MAT as proposed by the CLM TPCR team (First Line of Defense)
  • Assistance negotiating Third Party agreements to ensure performance and credit risks are properly identified, mitigated, approved, and monitored
  • The review/​challenge/​confirmation of Adverse Results Financial Risk Assessment control completed by the BAO for External Third Parties with financial capacity to perform rating of Poor

Enterprise Support

Enterprise Support covers activities that are outward facing from the organizational unit in which the activities take place. It supports Citi’s firm-wide control environment by providing advisory services and may also design, implement, review, and oversee firm-wide control programs.

Citi TPM, as part of Enterprise Support, is responsible for establishing Citi’s overall Third Party Management Policy, as well as overseeing its successful implementation throughout Citi. TPM provides management and mitigation of risk associated with Citi’s use of third parties.

Note: TPM FRA team falls under Enterprise Support, although it performs key First Line of Defense activities as previously mentioned.

Third Line of Defense


Internal Audit provides assurance services through the following approaches:

  • Analyzes Operations
  • Reviews Compliance
  • Assesses Safeguards

Check Your Understanding

Third Party Credit Risk Group is part of which Line of Defense?

Select the best response and then select Submit.

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Coming Next

We’ve looked at the various stakeholders, now we’ll take an in-depth look at the activities of the TPCRG.

TPCRG in Action

Approval of Third Party Credit Risk Management Action Trigger (TPCR MAT)


TPCR exposure arises when there is an agreement with an External Third Party to either hold, settle, prepay, or collect Citi funds, where some form of a guarantee or commitment is given to Citi by an external third party, or a liability to Citi exists as a result of an external third party relationship.

Identification of TPCR
TPCR is identified via the BAO’s answer of “Yes” to questions # 9 in Citi’s TP-RAP. TPCRG reviews and challenges the calculation of TPCR exposure.

Approval of TPCR MAT
TPCRG approves TPCR exposure (TPCR MAT) via the CAM. Approval level authority is governed by Wholesale Credit Risk Framework.

Confirmation of Financial Capacity to Perform Rating

TPPR refers to an External Third Party’s financial capacity to perform its obligations under the contract(s) with Citi.

The following third party relationships are in Scope for TPCRG’s review of TPPR:

  • External Third Parties rated Tier 1, Tier 2, or Tier 3 relationship as derived from Citi’s TP-RAP.
  • External Third Parties rated Tier 4 and Tier 5 by TP-RAP that are critical (including Continuity of Business/CoB: Franchise Critical, Criticality 1 or 2).

To proceed, select each item to learn about steps in the Third Party Performance Risk process.

 

Financial Analysis

The First Line of Defense (CLM TPCR or TPM FRA) prepares a financial analysis of the Third Party focusing on items such as key ratios, leverage, profitability, and liquidity. The financial analysis includes a Financial Risk Rating as well as a Financial Capacity to Perform (FCP) rating of: Strong, Adequate, Marginal, or Poor.

Confirmation of Spend Amount

A comparison of the Last Twelve Months (LTM) Spend with the proposed Spend amount for the next 12 months is reviewed and challenged by TPCRG.

Contract Analysis

A detailed evaluation of the Master Agreement(s) and relevant child Work Orders is performed for in-scope relationships. The reviews ensure the inclusion/absence of certain clauses that either:

  1. Don’t expose Citi to risk, OR
  2. Mitigate specific risks that have been identified.

These clauses include Termination Rights, Audit Rights, Subcontractor restrictions, Financial Reporting, Guarantees, or Third Party Credit Risk.

Exit Strategy Plan

An Exit Strategy Plan (ESP) defines alternatives if a Third Party fails. The ESP provides a framework and timeframes to ensure continuity of services should a third party be unable to provide products/services.

During the risk assessment process, the feasibility of the ESP is checked and potential issues are communicated to the stakeholders.

Other Considerations

In addition to the aspects we just discussed like Contract Analysis and Exit Strategy Plan, there are other considerations within Third Party Credit Risk and Third Party Performance Risk.

To proceed, select each icon to learn more about these considerations.

Operational Risk
 

If TPCRG identifies a potentially elevated level of Operational Risk, partners in Operational Risk Management (ORM) will be engaged to review.

For example:
A supplier managed a rebate program for Cards. The contract called for Citi to pre-fund rebates. The Business advanced money to the supplier without controls or protection provisions and the money was deposited to the supplier’s operating account. ORM helped the Business design a less risky process for prefunding rebates.

Reputation Risk
 

Also called “Headline Risk.” Could a supplier’s failure have negative repercussions for Citi’s reputation?

For example:
Suppliers are chosen as Trustees of Citi pension programs. Although Citi has no legal liability should a trustee misappropriate pension funds, it could damage Citi’s reputation if a Trustee with previous legal issues were engaged.

Check Your Understanding

Which step in the TPPR processes defines alternatives if a Third Party fails?

Select the best response and then select Submit.

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Coming Next

You’ve learned all about the role of the Third Party Credit Risk Group. Before taking the assessment, please review the key takeaways in the conclusion that follows.

Conclusion

Key Takeaways

To proceed, select each button to review the key learning points.

 

Third Party Credit Risk (TPCR)

  • TPCR arises when there is an agreement for an External Third Party to hold, collect, prepay or settle Citi Funds that could result in potential financial loss to Citi due to third party failure or inability to perform.
    • It is the responsibility of each Citi business or global function to identify TPCR in its own organization. The TP-RAP process assists with identifying TPCR.

Third Party Performance Risk (TPPR)

  • TPPR refers to an External Third Party’s financial capacity to perform its obligations under the contract(s) with Citi.

Third Party Management (TPM) Role

  • TPM plays an important role in managing and mitigating risks associated with Citi’s use of third parties.
    • TPCRG is one of the control groups in the TPM process.
    • TPCRG is responsible for the review/challenge of the financial analysis, credit approval process, and global portfolio management of in-scope providers of products and services to Citi.

TPM Stakeholder Roles and Responsibilities

  • TPM Stakeholders have roles and responsibilities in the TPM Lines of Defense Construct, which includes 5 levels:
    • Risk Accountable (BAOs, TPOs)
    • First Line of Defense (TPM FRA, CLM TPCR)
    • Second Line of Defense (TPCRG)
    • Enterprise Support
    • Third Line of Defense
  • Stakeholders have responsibilities in the initial supplier selection and ongoing monitoring processes.

TPCRG Activities

  • TPCRG focuses on the following aspects of TPCR and TPPR:
    • Approval of TPCR exposure
    • Financial analysis
    • Confirmation of FCP Rating
    • Confirmation of Spend amount
    • Exit Strategy Plan

Coming Next

Next up, there’s a five-question assessment.

Assessment

Citi uses a large number of External Third Parties to support business operations, client-facing processes and to deliver innovative products and services. Failure to assess and manage the level of risk and complexity of these Third Party relationships may lead to:

Select the best response from the three options and then select Submit.

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In the Lines of Defense Construct, which level is used to describe any role and responsibility that generates risk?

Select the best response from the four options and then select Submit.

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Third Party Credit Risk arises in which of these situations?

Select the best response from the four options and then select Submit.

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In the Third Party Risk Assessment Process (TP-RAP), which of these requirements for products/services will trigger TPCR?

Select the best response from the three options and then select Submit.

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Which of these roles are designated as risk accountable in the Third Party Management process?

Select the best response from the four options and then select Submit.

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TPCRG’s activities include which of the following?

Select the best response from the four options and then select Submit.

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In the Third Party selection due diligence and ongoing monitoring processes, which unit is responsible for completing the initial financial analysis of Third Parties?

Select the best response from the four options and then select Submit.

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There are several categories of Third Party Credit Risk within Citi. Examples of which TPCR category include advancement of funds for software licensing, system maintenance or employee healthcare services?

Select the best response and then select Submit.

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As part of Second Line of Defense, TPCRG is responsible for:

Select the best response from the four options and then select Submit.

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Which of the following questions on the Third Party Risk Assessment Process (TP-RAP) is asked to detect the presence of Third Party Credit Risk (TPCR)?

Select the best response from the four options and then select Submit.

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Assessment Results

Home
Third Party Credit Risk Fundamentals

Welcome
Third Party Credit Risk Group
Third Party Management
Stakeholder Roles and Responsibilities
Third Party Credit Risk Group (TPCRG) in Action
Conclusion
Assessment

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