Vendor Risk Management Program

Last updated: May 11, 2026

1. Purpose

This Vendor Risk Management Program ("VRM") governs how RAVEN selects, contracts with, and oversees third-party service providers that receive or process customer information. It is designed to satisfy the service-provider oversight requirements of the GLBA Safeguards Rule (16 CFR §314.4(f)), the FFIEC Outsourcing Technology Services booklet, and the data-aggregator and downstream-party obligations of 12 CFR Part 1033.

2. Scope

This program applies to all third-party providers that (a) receive or process consumer information on RAVEN's behalf, (b) provide infrastructure that handles consumer information in transit or at rest, or (c) provide identity, authentication, or operational services that materially affect platform security. The current list of subprocessors is published at /legal/subprocessors.

3. Subprocessor Selection

Before engaging a new subprocessor, RAVEN evaluates:

4. Required Contractual Terms

Every subprocessor contract must include:

5. Ongoing Oversight

6. Customer Notification of Subprocessor Changes

RAVEN maintains the public list of subprocessors at /legal/subprocessors. RAVEN will provide notice to active customers of material additions to or replacements of subprocessors that receive consumer data, in accordance with the Customer Agreement and applicable law. Customers may object to a new subprocessor under the terms of their Customer Agreement.

7. Termination and Offboarding

When a subprocessor relationship ends, RAVEN ensures that:

8. Program Maintenance

The Qualified Individual under the WISP owns this program. It is reviewed at least annually and after any material change to the subprocessor population, the regulatory environment, or RAVEN's product scope.

9. Contact