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Managing Risks in Third-Party Payment Processor Relationships

3 supervisory Insights Summer 2011 Managing Risks in Third-Party Payment Processor RelationshipsDuring the past few years, the Federal Deposit Insur-ance Corporation (FDIC) has observed an increase in the number of deposit Relationships between financial institutions and Third-Party Payment processors and a correspond-ing increase in the Risks associated with these Relationships . Deposit rela-tionships with Payment processors can expose financial institutions to Risks not present in typical commer-cial customer Relationships , including greater strategic, credit, compliance, transaction, legal, and reputation risk.

Supervisory Insights Summer 2011 Managing Risks in Third-Party Payment Processor Relationships D uring the past few years, the Federal Deposit Insur- ... merchant will engage in high pressure and deceptive sales tactics, such as aggressive telemarketing or enticing and misleading pop-up advertisements on Web sites. For example, consum-

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