Introduction

Centurion TPM is the TPM solution that is strategically aligned with OCC Bulletin 2013-29 (et al) to deliver a scalable, customizable,  powerful, comprehensive, cohesive, and effective real time Third Party Risk Management Program that is sure to please regulators.  In fact, we guarantee it.¹ How CENTURION Works 1. Centurion  presents a credible detailed strategic plan which can be quickly implemented, providing an effective response to regulators. 2. Centurion works with any governance structure and will easily adapt to a changed environment. 3. Centurion leverages the Bank’s current TPM system, capitalizing on the investment already made in existing architecture. 4. Centurion exists as an overlay; it will not be part of the Bank’s core system, thus it will not use any bandwidth; rather, it will be a Cloud-based SaaS application consisting of a pure golden source repository and database of TPM critical components that have been risk-assessed and risk-rated (i.e., validated). 5. Centurion provides a centralized risk nerve center (i.e., Centurion Station)  which is the heartbeat of the program, staffed by MCE employees (through its staff augmentation services), saving the Bank significant staffing expense. These employees (called “Centurions”) are experienced, highly trained risk specialists who arrive at the Bank fully trained and are productive the first day. Input into the Centurion system will be restricted to authorized MCE Officers and Bank Centurions to ensure the data remains pure and the program remains in regulatory compliance. 6. Centurion introduces independent review as BAU throughout the TPM process  by implementing Centurion reviews of all risk ratings being generated, which will provide an effective 2^nd line of defense sure to please the regulators. 7. Centurion provides an automated real-time dashboard which will provide decision makers with real-time validated risk ratings, along with options for actionable steps to mitigate risks, and heat maps to instantly identify high risk areas. Access to view Centurion’s dashboard and risk profiles will be available to all critical TPM roles. Searches will be limited to authorized categories: Supplier, Parent, Country, Category, BSRM, SMC, Keyword, etc. 8. Centurion Ratings are generated by an algorithm applied to each risk factor reviewed: Raw Risk Rating x Assigned Weight = Weighted Rate (WR), which is then compared to the Bank’s Comfort Setting (CS). The Bank chooses its Comfort Setting  according to its risk appetite: Low Risk (1-2), Moderate Low (2-3), Moderate High 3-4) and High Risk (4-5). 9. Centurion monitors regulatory compliance by comparing the Weighted Rate  (WR) to the Bank’s Comfort Setting (CS).  If WR is less than or equal to CS, the response will be “Approved.” If WR is greater than CS, Centurion’s response will be either “Remediate” or “EDD.” Items that need remediation will be (1) returned to the BSRM along with remediation tips and a due date and (2) calendared with email alerts. Some risk factors are not remediable; those will have a result of “EDD” (Enhanced Due Diligence) which means they are approved with close monitoring. 10. Centurion also provides world class training to all layers of the Bank’s TPM program to ensure a thorough understanding of all governance, regulations, risk assessment, and mitigation strategies so that all decisioning is based on sound reasoning supported by real-time information. 11. Centurion performs the TPM risk assessment role required by regulators, providing the Bank’s strategic and tactical TPM managers (i.e., Boards, Senior Managers, SMCs, and BSRMs) the knowledge and information they need to make informed decisions. This partnership creates a well balanced and effective TPM risk management program. 12. Centurion provides Board Members and Senior Management with real-time detailed and summary information about the Bank’s TPM program and will simplify their required involvement in the process and provide an easy audit trail for regulators. 13. Centurion provides regulators with an easy-to-follow traceability map so they can see where and how their regulations are being implemented, a feature the regulators will appreciate. 14. Centurion provides a full audit trail, audit transparency, and documented edit history to facilitate audits and examinations. ¹ Guarantee is dependant on Bank’s full implementation and compliance with the provisions of Centurion TPM.