Alpha Covenant Holdings · Duty Sheet · generated 2026-10-25 18:47 UTC · free · all sheets

Interagency Guidance on Third-Party Relationships: Risk Management (OCC Bulletin 2023-17; FDIC FIL-29-2023; FRB SR 23-4) — ongoing monitoring record

Applies to: Banks, savings associations and credit unions and their vendor-management teams; examiners reviewing the third-party file · Rule text: https://www.occ.gov/news-issuances/bulletins/2023/bulletin-2023-17.html

The question the rule asks

The guidance expects a bank to perform ongoing monitoring of third parties through the life of the relationship — including the third party's legal and regulatory compliance and public enforcement actions — and to document it so examiners can see what was checked and when. It names no particular database; the bank chooses, and must be able to show the record.

The party this sheet is about

American National Red Cross · keys supplied: UEI G69LHXJ3ABL5 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_d1ecaffc2e6d4549 · read 2026-10-25 18:47:50 UTC · SHA-256 4e5ac704d5ea0b5af343667c87aec8f59f0a59bbaa26ff9f0750ec2fc0b56ea2 · verify: https://alphacovenantholdings.com/r/r_d1ecaffc2e6d4549

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
SAM.gov Exclusions — Public Extract V2 (GSA, daily)answers the questionanswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-25 (SAM_Exclusions_Public_Extract_V2_26298.ZIP).
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)answers the questionanswered0No entry under this exact name or listed alias on the SDN list fetched 2026-10-24.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directlyanswers the questionanswered00 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
CFPB Consumer Complaint Database (company field equals this exact name as the CFPB prints it)supportinganswered0No complaint in the CFPB database where the company field equals this exact name.
SEC EDGAR (registrant submissions index, data.sec.gov)supportinganswered0EDGAR's entity index lists no registrant under this exact printed name (a registrant may file under a different printed name — see the EDGAR company search).
Federal Audit Clearinghouse (GSA) — single audit filings under 2 CFR 200 Subpart Fsupportinganswered3 single-audit filing year(s) on file; latest FY2025: 0 finding(s), material weakness No
EPA ECHO (Enforcement and Compliance History Online) — facility recordssupportinganswered2ECHO returned 7 facility record(s) for a name search on 'American National Red Cross'; 2 carry this exact printed name. Each row links to EPA's own Detailed Facility Report.
HHS OCR breach portal (covered-entity name equals this name)supportingansweredNo breach report filed under this exact name in the portal's current list.
IRS Tax Exempt Organization Search — Automatic Revocation of Exemption list and Publication 78 data (bulk files)supportinganswered22 automatic-revocation entries under this exact printed legal name. Publication 78: listed as PC.
HHS Office of Inspector General — LEIE (monthly downloadable file)supportinganswered0No entry under this exact name in the OIG file fetched 2026-10-25.

What to record in the file

A dated receipt per third party, re-read monthly by roster with the line-by-line changes since the prior month: SAM exclusions, OFAC SDN and the Consolidated Screening List with file dates; the CFPB complaint count where the company field equals the exact name (candidates listed, not counted); SEC EDGAR filings by CIK; FAC, ECHO, OCR and IRS rows as printed. The receipt records the read; the risk assessment, criticality tier and conclusion are the bank's own and belong in the bank's file, not on this page. FinCEN beneficial-ownership data is not public and is not read.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections